Tekoh v. County of Los Angeles
United States Court of Appeals for the Ninth Circuit
75 F.4th 1264 (2023)
- Written by Jamie Milne, JD
Facts
Terence Tekoh (plaintiff) sued Deputy Sherriff Carlos Vega (defendant) for damages under 42 U.S.C. § 1983, alleging that Vega violated the Fifth Amendment by coercing a confession from Tekoh. Tekoh alleged that Vega lied about the existence of video evidence, used racial slurs and threats of deportation, and approached Tekoh with his hand on his gun. Vega denied engaging in such coercive tactics. Tekoh planned to call Dr. Iris Blandón-Gitlin, an expert on coerced confessions, to testify at trial. Blandón-Gitlin would have testified how tactics such as those allegedly employed by Vega could have elicited a false confession. Blandón-Gitlin would have also testified about how the text of Tekoh’s confession, which included statements of apology and excuse, could indicate that the confession resulted from coercive tactics. The district court excluded Blandón-Gitlin’s testimony, holding that it lacked probative value and would impermissibly vouch for Tekoh’s credibility. The jury subsequently ruled against Tekoh, and Tekoh appealed, contesting the district court’s decision to exclude Blandón-Gitlin’s testimony.
Rule of Law
Issue
Holding and Reasoning (Wardlaw, J.)
Dissent (Miller, J.)
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