CA5: Expert opinion on reasonableness in 1983 case improper

“We first find that the district court did not abuse its discretion in excluding portions of testimony from two of Albert’s expert witnesses—Richard Lichten, a police-procedure expert, and Dr. Kris Sperry, the former Chief Medical Examiner for the State of Georgia. The district court held that three of Lichten’s opinions were inadmissible conclusions of law. See United States v. Williams, 343 F.3d 423, 435 (5th Cir. 2003) (‘Reasonableness under the Fourth Amendment or Due Process Clause is a legal conclusion.’); McBroom v. Payne, 478 F. App’x 196, 200 (5th Cir. 2012) (per curiam) (explaining that experts are not ‘permit[ted] … to offer legal conclusions, and whether an officer’s use of his firearm was unreasonable for purposes of the Fourth Amendment is a legal conclusion’ (citation omitted)). We agree.” Albert v. City of Petal, 2020 U.S. App. LEXIS 19673 (5th Cir. June 22, 2020).