## Facts

- Kimberly Pyles worked as a dancer at Rick’s Cabaret in New Orleans.
- While Pyles performed on stage, patron Anthony Weaver approached her and offered money for her to expose her body.
- Pyles ended her routine early and left the stage to report Weaver’s conduct to club personnel.
- As Pyles walked away, Weaver threw a heavy glass that struck her in the face, causing injuries.
- Pyles sued Weaver and Rick’s Cabaret entities, alleging Rick’s failed to provide adequate security and to protect her from foreseeable patron misconduct.
- At trial, Pyles offered Larry Preston Williams as a security expert to opine that the club’s security was inadequate and contributed to the injury; Rick’s objected to his qualification.

## Issues

1. Whether the trial court abused its discretion by qualifying Larry Preston Williams as an expert in security and allowing his testimony regarding the adequacy of the club’s security measures.
2. Whether an alleged conflict of interest required the trial judge’s recusal or a new trial.

## Decision

- The Louisiana Fourth Circuit affirmed the judgment entered on the jury verdict.
- The court held the trial court did not abuse its discretion in qualifying Williams as a security expert under Louisiana Code of Evidence article 702.
- The court held the asserted judicial conflict did not require recusal and did not warrant a new trial; denial of post-trial relief was not an abuse of discretion.
- The jury’s allocation of fault and damages against Rick’s and Weaver remained intact.

## Legal Principles

- Under La. Code Evid. art. 702, expert testimony is admissible when specialized knowledge will assist the trier of fact and the witness is qualified by knowledge, skill, experience, training, or education.
- A trial court’s decision to qualify an expert is reviewed deferentially and will be reversed only for manifest error or abuse of discretion.
- Weaknesses in an expert’s credentials generally affect the weight of the testimony and are addressed through cross-examination and competing expert proof, not automatic exclusion.
- Judicial recusal and new trial relief based on alleged conflicts require a showing that the interest or bias would prevent fair and impartial adjudication; speculative or attenuated connections are insufficient.

## Conclusion

The court affirmed a negligent-security verdict arising from a patron assault at a nightclub, ruling that the trial judge permissibly admitted the plaintiff’s security expert testimony under the liberal qualification standard of Louisiana evidence law and that the asserted judicial conflict did not justify recusal or a new trial.


Pyles v. Weaver, 958 So. 2d 753 (La. Ct. App. 4th Cir. 2007)