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Anthropologists

Admissibility Rate: .000    (0/1)

United States v. Mamah, 332 F.3d 475 (7th Cir. 2003).  While in police custody, Ghanaian immigrant confesses to drug possession.  He later recants.  At trial, he calls anthropologist (Dr. Deborah Pellow) and sociologist (Dr. Richard Ofshe) to opine that Ghanaians are confession-prone, because Ghana is governed by oppressive military regime.  District court excludes testimony because: (1) neither expert is clinical psychologist qualified to assess defendant's susceptibility to interrogation techniques; (2) defendant has lived in United States for over fifteen years; and (3) defendant did not show similarity between tactics used by arresting officers and interrogation techniques in Ghana.  Jury convicts and defendant appeals.  Exclusions affirmed.  Testimony failed to satisfy Fed. R. Evid. 702.  Experts may have been qualified in their respective fields, and their research may have been methodologically sound, but they relied on insufficient facts or data to link their theories to facts of case, which involved non-coercive interrogation in America, not coercive interrogation in Ghana.

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