USA v. Wilson

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Case 3:24-cr-00239-MEM Document 85 Filed 11/17/25 Page 1of8

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA
Vv. : 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 expert testimony of Dr. Stephen Timchak, a psychologist for the
defense. (Doc. 78). For the reasons stated herein, the Government's motion
will be GRANTED, and the witness will be precluded from testifying.
Additionally, Defendant will be precluded from himself testifying to his mental
abnormalities and any link between them and the offenses charged, and
defense counsel will be precluded from making any argument directing the
jury to consider whether evidence of Defendant's mental abnormalities
negates mens rea.

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

AUTHENJICATED

Case 3:24-cr-00239-MEM Document 85 Filed 11/17/25 Page 2of8

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 November 10, 2025, Defendant notified the Government that he
wishes to offer the expert testimony of Dr. Timchak at trial, pursuant to Rule
702 of the Federal Rules of Evidence. (Doc. 79-1). He indicated that Dr.
Timchak would testify to Defendant's symptoms consistent with Post
Traumatic Stress Disorder (“PTSD”). /d. Defendant’s notice also outlined Dr.
Timchak’s experience and training as a psychologist. /d.

On November 12, 2025, the Government filed the present motion in
limine to preclude Dr, Timchak’s testimony, as well as its brief in support.
(Docs. 78-79). On November 13, 2025, Defendant filed his brief in
opposition. (Doc. 83). Finally, on November 14, 2025, the Government filed
its reply brief. (Doc. 84). Thus, the motion is ripe for review.

lH. 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.” /d. Evidentiary

2.

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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.” Rido/ffi v. State Farm Mutual Auto. Ins. Co.,
2017 WL 3198006, *2 (M.D.Pa. 2017). Further, “[clourts may exercise this
discretion in order to ensure that juries are not exposed to unfairly prejudicial,
confusing or irrelevant evidence.” /d.

“A trial court considering a motion jn 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)).

Ill. DISCUSSION

18 U.S.C. §17(a) codifies the affirmative defense of insanity, stating:
“It is an affirmative defense to a prosecution under any Federal statute that,
at the time of the commission of the acts constituting the offense, the

defendant, as a result of a severe mental disease or defect, was unabie to

-3-

Case 3:24-cr-00239-MEM Document 85 Filed 11/17/25 Page 4of8

appreciate the nature and quality of the wrongfulness of his acts. Mental
disease or defect does not otherwise constitute a defense.” Furthermore,
§17(a) precludes mental defect evidence that does not support a legally
acceptable theory of a lack of mens rea. United States v. Pohlot, 827 F.2d
889, 906 (3d Cir. 1987). Simply put, psychiatric evidence cannot serve as a
defense unless it renders the defendant legally insane, and even if the
defendant is deemed insane, such evidence is inadmissible unless it negates
the mens rea of the crime charged.‘

Here, the Government thoroughly analyzed this issue with respect to
the mens rea requirement of voluntary manslaughter in its brief in support.
Defendant did not dispute the Government's argument; instead, Defendant
narrowly focused on admissibility of the psychiatric evidence for purposes of
his self-defense claim. Thus, Defendant essentially conceded that his PTSD
evidence does not truly negate mens rea. Given Defendant’s concession,

the court need not exhaustively analyze the issue in the present

1 See Pohlot, 827 F.2d at 900 (“Only in the rare case, however, will
even a legally insane defendant actually lack the requisite mens rea purely
because of mental defect. As the House Report [on the Insanity Defense
Reform Act] stated: ‘Mental illness rarely, if ever, renders a person incapable
of understanding what he or she is doing. Mental illness does not, for
example, alter the perception of shooting a person to that of shooting a tree.’
Similarly, a man who commits murder because he feels compelled by
demons still possesses the mens rea required for murder.” (internal citations
omitted)).

-4.

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memorandum. However, the court notes that it agrees with the
Government’s analysis that the PTSD evidence does not negate the mens
rea for voluntary manslaughter and is thus inadmissible.? Simply, PTSD does
not constitute insanity, nor does PTSD negate the mens rea for voluntary
manslaughter. The court posits, as a theory, that PTSD could have inflamed
Defendant’s reaction such that he carried out the killing in the heat of
passion. In other words, PTSD likely offers an explanation, not a negation.

While the court’s analysis need not go further—as Defendant neither
claims he is insane, nor that the relevant mens rea was negated by his
mental condition—the court will briefly address Defendant’s argument that
the PTSD evidence should be admitted for purposes of a self-defense
argument.

In making his argument, Defendant relies on exclusively nonbinding
out-of-circuit case law pertaining to battered woman's syndrome and duress.
(Doc. 83). Defendant uses this case law to argue that because expert

psychiatric testimony may be admissible in duress cases involving battered

2 Specifically, the court agrees that “At best, [Defendant's] PTSD gives
the jury an explanation for why he had the intent or reckless mental state to
kill Spence in the heat of passion, not that he did not have the relevant mens
rea.” (Doc. 79 at 13-14). Nothing in Dr. Timchak’s report indicates that the
mens rea was negated. It merely indicates that Defendant may have an
underlying condition that explains why he was able to carry out a killing.

5.

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woman’s syndrome, such testimony should also be admissible in self-
defense cases involving PTSD. The court disagrees.

As noted, the PTSD evidence does not negate mens rea, so it is
inadmissible. Furthermore, Defendant's analogous reasoning does not hold
up under scrutiny. As the Government notes,

Battered woman’s syndrome focuses on the perceived threat
posed by the batterer on the battered, while PTSD, as shown
by Dr. Timchak’s report, focuses on a more general,
perceptual perceived threat posed to the PTSD-sufferer by his
surroundings .. . Here, [Defendant] was not under duress or
defending himself against his “batterer” or someone who had
assaulted him in the past. So [Defendant’s] PTSD is much less
probative to the disputed issues here than those in the cases

relied on by the defendant.

(Doc. 84 at 5). Further, the burden of proving insanity is Defendant's.
Defendant has failed to do so. Finally, “[sjelf-defense hinges on the
reasonableness of the defendant's subjective beliefs.” Gov't of V.I. v. Smith,
949 F.2d 677, 684 (3d Cir. 1991). Self-defense requires the jury to assess
Defendant’s actions by asking what an average reasonable person in
Defendant's situation would do. This is an objective inquiry. It does not

require the jury to ask what a reasonable person with PTSD would do, nor

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what Defendant should be expected to do given his condition. Thus,
Defendant’s arguments fail.

Finally, even if the court were to find that PTSD negates the mens rea
of voluntary manslaughter in this case, the psychiatric evidence would still
be inadmissible as both irrelevant, under Rule 402 of the Federal Rules of
Evidence, and confusing to the jury, under Rule 403. As the Government
notes, Defendant's “proposed psychiatric evidence will tend to mislead the
jury and confuse the issues by having the jury focus on [Defendant's]
subjective psychological trauma and general PTSD symptoms as opposed
to the objective reasonableness of his reaction .. . [or,] the PTSD evidence
could lead a juror to excuse [Defendant's] conduct.” (Doc. 79 at 19). The
court agrees and finds that the evidence would confuse or mislead the jury.
Furthermore, the jury will employ an objective standard in analyzing the
reasonableness of Defendant’s actions for both heat of passion and seif-

defense purposes. Therefore, the psychiatric evidence is irrelevant.

Case 3:24-cr-00239-MEM Document 85 Filed 11/17/25 Page 8of8

IV. CONCLUSION
For the foregoing reasons, the Government's motion will

GRANTED. An appropriate order shall issue.

A>

MALACHY\E. MANNION
United States District Judge

DATE: ufryfrs

24-239-03

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