USA v. Wilson

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA 	:
v. 	: 	CRIMINAL NO. 3:24-239
BRYANT WILSON, 	: 	(JUDGE MANNION)
Defendant 	:
MEMORANDUM
Pending before the court is the Government’s motion in limine to
preclude the testimony of Mr. Paul Gibson, a prison expert for the defense.
(Doc. 69). For the reasons stated herein, the Government’s motion will be
GRANTED, and the witness will be precluded from testifying.
I. 	BACKGROUND
Defendant Bryant Wilson (hereinafter “Defendant”) is charged with
voluntary manslaughter, in violation of 18 U.S.C. §1112, and possession of
contraband in prison, in violation of 18 U.S.C. §1791(a)(2), following a prison
fight at USP Canaan that resulted in the stabbing death of Defendant’s victim
on November 28, 2021. (Doc. 1). Defendant does not contest that the fight
happened, nor that the death of his victim resulted; rather, he asserts that he
acted in self-defense.
On October 17, 2025, Defendant notified the Government that he
wishes to offer the expert testimony of Gibson at trial, pursuant to Rule 702
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of the Federal Rules of Evidence. (Doc. 69-1). He indicated that Gibson
would testify to the following:
1. It is proper procedure for correctional officers at a high
security USP, including USP Canaan, to secure the area
and 	request 	the 	assistance 	of 	additional 	staff 	before
breaking up a physical altercation between inmates.
2. At a USP, it is common for other inmates to join an attack
on another inmate after it has been initiated.
3. High security USPs, including USP Canaan, is a dangerous
place where inmates are at risk of serious bodily injury or
death by other inmates every day.
4. Due to the dangerous environment at high security USPs,
including USP Can[a]an, it is common for inmates at these
facilities to carry a weapon or have access to a weapon.
(Doc. 69-1 at 3). Defendant’s notice also outlined Gibson’s experience as a
former BOP worker for 32 years. (Doc. 69-1).
On October 23, 2025, the Government filed the present motion in
limine to preclude Gibson’s testimony, as well as its brief in support. (Docs.
68-69). The Government also provided the court with security camera
footage from USP Canaan of the incident at issue. (Doc. 70).
On November 6, 2025, Defendant filed his brief in opposition. (Doc.
69).
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While the Government’s reply brief is due November 20, 2025, trial is
set for November 17, 2025. Furthermore, the court does not find that a reply
brief is necessary to rule on the present motion. Thus, the motion is ripe for
review.
II. 	LEGAL STANDARD
“The purpose of a motion in limine is to allow the trial court to rule in
advance of trial on the admissibility and relevance of certain forecasted
evidence.” United States v. Tartaglione, 228 F.Supp.3d 402, 406 (E.D.Pa.
2017). On a motion in limine, evidence should only be excluded “when the
evidence is clearly inadmissible on all potential grounds.” Id. Evidentiary
rulings on motions in limine are subject to the trial judge’s discretion and are
therefore reviewed for an abuse of discretion. Abrams v. Lightolier, 50 F.3d
12-4, 1213 (3d Cir. 1995); Bernardsville Bd. Of Educ. V. J.H., 42 F.3d 149,
161 (3d Cir. 1994). “The Court is vested with broad inherent authority to
manage its cases, which carries with it the discretion and authority to rule on
motions in limine prior to trial.” Ridolfi v. State Farm Mutual Auto. Ins. Co.,
2017 WL 3198006, *2 (M.D.Pa. 2017). Further, “[c]ourts may exercise this
discretion in order to ensure that juries are not exposed to unfairly prejudicial,
confusing or irrelevant evidence.” Id.
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“A trial court considering a motion in limine may reserve judgment until
trial in order to place the motion in the appropriate factual context.” United
States v. Tartaglione, 228 F.Supp.3d at 406. “Further, a trial court’s ruling on
a motion in limine is ‘subject to change when the case unfolds, particularly if
actual testimony differs from what was contained in the movant’s proffer.’”
Id. (quoting Luce v. United States, 469 U.S. 38, 41 (1984)).
III. 	DISCUSSION
Central to the issue here is Rule 702 of the Federal Rules of Evidence,
which provides that:
A witness who is qualified as an expert by knowledge, skill,
experience, training, or education may testify in the form of an
opinion or otherwise if the proponent demonstrates to the court
that it is more likely than not that:
(a) the expert’s scientific, technical, or other specialized
knowledge will help the trier of fact to understand the
evidence or to determine a fact in issue;
(b) the testimony is based on sufficient facts or data;
(c) the testimony is the product of reliable principles and
methods; and
(d) the expert’s opinion reflects a reliable application of
the principles and methods to the facts of the case.
Fed. R. Evid. 702. As the Government notes, “[d]istilled to its essence, ‘Rule
702 embodies a trilogy of restrictions on expert testimony: qualification,
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reliability, and fit.’” (Doc. 69 at 4) (quoting In re Johnson & Johnson Talcum
Powder Prods. Mktg., Sales Pracs. & Prods. Litig., 509 F.Supp.3d 116, 130
(D.N.J. 2020).
While the parties make arguments regarding reliability, an analysis of
fit alone is sufficient here. Fit requires that expert testimony be helpful, i.e.,
“sufficiently tied to the facts of the case [such that] it will aid the jury in
resolving a factual dispute.” United States v. Schiff, 602 F.3d 152, 173 (3d
Cir. 2010). The court will assess each of the opinions that Defendant
indicated that Gibson “is expected to testify to,” (Doc. 69-1 at 3), under the
fit prong of Rule 702.
a. Proper staff procedure for a physical altercation at a high
security federal prison
Defendant expects Gibson to testify that “It is proper procedure for
correctional officers at a high security USP, including USP Canaan, to secure
the area and request the assistance of additional staff before breaking up a
physical altercation between inmates.” (Doc. 69-1 at 3). Such an opinion will
be precluded as it will not help the jury “to understand the evidence or
determine a fact in issue.” Fed. R. Evid. 702(a).
The actions of the correctional officers are not at issue in this case.
Defendant argues that their behavior is relevant to the issue of self-defense
because Defendant’s knowledge that the officers would not intervene tends
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to demonstrate that Defendant was reasonable in his actions because he
had a reasonable fear of death or serious bodily injury, and he had no
reasonable opportunity to avoid harm without committing the act. (Doc. 74 at
4) (internal citation omitted). Further, he argues:
It is certainly not intuitive to a lay person that a CO [correctional
officer] would not immediately attempt to break up a fight
between inmates or provide protection to an inmate who has
been attacked by another inmate. However, a 	reasonable
person in [Defendant’s] position, as an inmate who has been
incarcerated in federal prisons since 2002, knows that COs
follow this protocol.
Id. (emphasis in original). While the average lay juror would not know proper
staff procedures within a federal prison, the court disagrees that Gibson’s
testimony on the matter is necessary.
The security camera footage of the incident clearly shows that officers
did not and were not going to intervene in the fight. Whether or not it was
proper protocol is irrelevant. Further, Defendant’s knowledge or lack thereof
of protocol is similarly irrelevant, as the reality of non-intervention in that
moment was clear. The jury will be able to watch the events unfold, assess
the lack of intervention, and determine whether the lack of intervention made
Defendant’s actions reasonable, without need for Gibson’s testimony.
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b. Likelihood 	of 	additional 	prisoners 	engaging 	in 	an
ongoing altercation
Defendant also expects Gibson to testify that “At a USP, it is common
for other inmates to join an attack on another inmate after it has been
initiated.” (Doc. 69-1 at 3). Such testimony would be irrelevant, confusing, a
waste of time, and unhelpful to the jury.
The security camera footage clearly shows all other inmates in the area
swiftly return to their cells when Defendant and the victim began fighting. In
the court’s opinion, there was no imminent threat of harm from any additional
prisoners to Defendant, nor any reason for Defendant to expect there was.
Furthermore, to the extent there was any, the court is not persuaded that
such a threat has any tendency to make Defendant’s actions with respect to
the victim any more reasonable. Presenting evidence about the likelihood of
additional prisoners joining in the fight would only serve to confuse the
issues, as no one joined in here.
c. Dangerousness of high security federal prisons
Defendant further expects Gibson to testify that “High security prisons,
including USP Canaan, [are] [sic] dangerous place[s] where inmates are at
risk of serious bodily injury or death by other inmates every day.” (Doc. 69-1
at 3). The Government argues that “[t]here is no dispute that a high-security
federal prison is a ‘dangerous place’ properly defined,” and that jurors’
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common sense will inform them of the dangers of federal prison. (Doc. 69 at
9). In response, Defendant argues that “[t]he assumption that jurors will be
aware of the danger of physical violence faced by inmates at USP Canaan
is purely speculative. To the contrary, jurors may presume a ‘high security’
prison means highly secure or safe.” (Doc. 74 at 6).
Having Gibson testify as to the dangerousness of a high security prison
would unquestionably waste the jury’s time. Common sense does indeed
lend itself to a presumption that prison is dangerous, regardless of the
security level. Furthermore, to the extent that a juror may think a high security
prison is somehow safe, they will not need an expert to dispel such a notion
at trial. As the Government aptly puts it: “the jury will be able to glean from
the [security camera footage] the dangerousness of USP Canaan, as they
observe [the victim] approach with a combination lock and [Defendant] stab
him to death with a shank.” (Doc. 69 at 9). Indeed, the dangerousness of
prison is inherent to this case.
d. Commonality of armed inmates at high security federal
prisons
Finally, 	Defendant 	expects 	Gibson 	to 	testify 	that 	“[d]ue 	to 	the
dangerous environment at high security USPs, including USP Can[a]an, it is
common for inmates at these facilities to carry a weapon or have access to
a weapon.” (Doc. 69-1 at 3).
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The court finds that such testimony would also be irrelevant and
unhelpful to the jury. Common sense, again, leads to the conclusion that
inmates 	often 	possess 	weapons 	such 	as 	“shanks.” 	Furthermore, 	that
Defendant and the victim had weapons is clear from the security camera
footage. Finally, the court does not see how the commonality of weapon
possession in prison has any bearing on this case. Such information does
not connect to any element of the crimes charged or aid in any defense.
IV. 	CONCLUSION
For 	the 	foregoing 	reasons, 	the 	Government’s 	motion 	will 	be
GRANTED. An appropriate order shall issue.
s/ Malachy E. Mannion
MALACHY E. MANNION
United States District Judge
DATE: November 13, 2025
24-239-02
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