In re Melton

District of Columbia Court of Appeals · 1991 · Evidence

597 A.2d 892 (D.C. 1991)

Updated August 22, 2026

Evidenceexpert testimonypsychiatristdangerousnesscivil commitmentRule 703hearsay basisreasonable reliance

Facts

Melton, diagnosed as a paranoid schizophrenic, had a history of failing to report for prescribed medication when not adequately supervised. Two hospital psychiatrists testified that when off medication he rapidly deteriorated, became psychotic, threatening, assaultive, unable to care for himself, and was found filthy, untreated for serious medical conditions, and in poor physical condition. In forming their opinions, the psychiatrists relied partly on personal observations and partly on reports from Melton's family and records of prior hospitalizations, including reports that he punched his mother, threatened his sister with a screwdriver, and had previously threatened self-harm. Both psychiatrists concluded that if released without hospital supervision, Melton was likely to injure himself or others.

Issue

Whether the trial court erred by permitting psychiatrists to testify that Melton was likely to injure himself or others without separately establishing special expertise in predicting dangerousness, and whether the court erred by permitting those experts to base their opinions on out-of-court statements from family members and hospital records without an explicit finding that such materials were reasonably relied upon by experts in the field.

Rule

Under Dyas, expert testimony is admissible when the subject is beyond the ken of the average layperson, the witness has sufficient skill, knowledge, or experience to aid the factfinder, and the state of the pertinent art permits a reasonable expert opinion. A qualified psychiatrist may testify about a patient's likely dangerousness without separate qualification in a special dangerousness subspecialty when the assessment is reasonably related to psychiatric practice. Under Rule 703 principles as applied in the District, an expert may base an opinion on inadmissible facts or data, including statements by relatives and hospital records, if they are of a type reasonably relied upon by experts in the particular field and satisfy minimal standards of reliability; objections to reliability ordinarily go to weight rather than admissibility unless no reasonable expert could rely on the material.

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At a civil commitment hearing in Washington, D.C., Dr. Lena Morris, a licensed psychiatrist who has treated Devin Cole for six months, testifies that if Devin stops attending his supervised medication appointments, he will likely become unable to care for himself and may injure others. Defense counsel objects that Dr. Morris has never completed a special fellowship in violence prediction.

How should the court rule on the objection?

Explanation. The objection should be overruled. Under the majority opinion, the Dyas framework governs expert admissibility, and a qualified psychiatrist need not show a separate specialty in predicting dangerousness before opining on whether a patient is likely to injure self or others. The key is that the assessment is sufficiently related to psychiatric practice and will aid the factfinder on a matter beyond ordinary lay knowledge.