Experts in Media: Primal Fear and Avoiding Absolutes 

By Noah Bolmer 

Primal Fear (1996) is a legal thriller about the trial of a young altar boy accused of murdering a prominent archbishop. While this gripping courtroom narrative features sharp turns, layered with psychological tension, we’ll examine how the movie depicts expert interactions, the challenges they face in cross-examination, and what these portrayals reveal about the expectations placed on experts in criminal litigation. 

Background 

Defense attorney Martin Vail (Richard Gere), a slick Chicago lawyer, takes on the high-profile case of Aaron Stampler (Edward Norton), a shy and stuttering altar boy accused of brutally murdering an Archbishop. The case quickly garners public attention, and Vail, known for his courtroom theatrics, sees an opportunity to challenge the system while defending a vulnerable client. As the trial begins, the prosecution, led by Janet Venable (Laura Linney) builds a case grounded in physical evidence and motive. 

Expert Testimony: Dr. Woodside 

Early in the proceedings, the prosecution calls Dr. Woodside (Brian Reddy), a forensic expert, to testify about the blood evidence found on Aaron’s clothing and at the crime scene. His testimony is intended to establish a direct physical link between Aaron and the murder, using scientific analysis to support the prosecution’s narrative. 

VENABLE: Dr. Woodside, the victim clearly suffered a great number of stab wounds. 

WOODSIDE: Yes, he did. Seventy-eight. He tried to defend himself, which explains the cuts on his hands and forearms. 

VENABLE: And your report concludes that the puncture wounds could have been fatal? 

WOODSIDE: One to the chest and one to the liver—but in my view, the throat wound was the fatal one. 

VENABLE: Dr. Woodside, is there any scientific question about whose fingerprints are on the knife and the walls? 

WOODSIDE: No. They belong to the defendant. 

Absolutes are dangerous in expert testimony. Surprising edge cases, contaminated evidence, and other unforeseen factors may come back to bite experts who do not qualify responses (or attorneys who do not qualify their questions). Nevertheless, Venable clearly set Woodside up to answer affirmatively, despite the risks of doing so.  

VENABLE: And the bloody footprints leading from the bedroom to the kitchen? 

WOODSIDE: The lethal throat incisions and many others were made from an angle strongly suggesting a left-handed person was using the knife. 

VENABLE: To your knowledge, is the defendant left-handed? 

WOODSIDE: Yes. He is. 

Here, while Woodside answers using the language of absolutes, he was prompted with “to your knowledge”, which is an escape clause. 

VENABLE: Based on the physical evidence at the crime scene, do you have an opinion to a reasonable degree of certainty as to the path the killer took through the apartment? 

WOODSIDE: I believe the killer entered the kitchen wearing gloves and took the carving knife from the drawer. A glove fiber was found on the knob. Then he went through the kitchen, entered the bedroom, and proceeded to attack the Bishop. 

VENABLE: Tell the jury what happened next, Dr. Woodside. 

WOODSIDE: The killer left a trail of bloody footprints that lengthen in distance moving away from the corpse. My analysis of this data suggests that the killer was startled by something during the mutilation and ran from the bedroom, down the stairs through the kitchen, and out. 

VENABLE: Thank you. No further questions at this time. 

Venable returns to her chair. Vail rises and comes around from the defense table. 

Note, typically the judge will prompt for re-direct before it happens. Nevertheless, Vail proceeds to put on full display the dangers of absolute language.  

VAIL: Doctor, can you swear that the same person and weapon made all the various cuts, slices, incisions, gouges, and punctures so graphically displayed in those photographs? 

WOODSIDE: Do you mean, is there a possibility someone else might have made some of them using an additional instrument? 

VAIL: Or instruments, yes. 

WOODSIDE: I can safely say a left-handed person used a knife as the murder weapon. 

Woodside is walking into a trap here. Without any hedging, he confidently states what happened without considering (or voicing the possibility of) alternative explanations. He might have better maintained his credibility with a simple “based on the available evidence, it is most likely that…” Of course, criminal trials often hinge on reasonable doubt, so there can be an inherent push-and-pull between wanting to close the door to doubts on one hand, and avoiding absolutes on the other.  

VAIL: Well, what about the two potentially lethal wounds you testified about? You described them as straight-in punctures, if I heard you right. 

WOODSIDE: That’s correct. 

VAIL: Isn’t it possible, Doctor, that those two puncture wounds could have been made by a right-handed person using an ice pick or some other such instrument? 

WOODSIDE: Anything is possible, Mr. Vail. 

Here, Woodside is backpedaling. He has gone from “I can safely say…” to “anything is possible”. This is exactly what Vail wanted the jury to see.  

VAIL: Yes or no, Doctor. Can you tell this court to a reasonable degree of scientific certainty that no one else was in that room at the time of the murder? 

WOODSIDE (pause): No. 

This is the payoff. An expert must, above all, remain honest and neutral. Woodside has no choice but to cede the point, contradicting his earlier absolute statement.  

VAIL: Thank you, Doctor. Now, one last question. You’ve been Cook County’s medical examiner how long? 

WOODSIDE: Twenty-three years. 

VAIL: Twenty-three years of examining countless murder sites? 

WOODSIDE: More than I care to remember. 

VAIL: Then tell me, when did you last determine that a killer opened a drawer wearing gloves, then removed those gloves to kill someone with his naked hand wrapped around the murder weapon? 

WOODSIDE (long pause): I’ll admit that it defies logic. 

VAIL: So will I, Doctor. No further questions. 

In the real world, this exchange would probably be followed by a re-direct to clean up some of Woodside’s testimony. When cross-examination doesn’t go well, it is best to maintain your demeanor and allow your attorney to get things back on track.  

Expert Testimony: Dr. Molly Arrington 

As the trial progresses and the defense begins to explore alternative explanations for Aaron’s behavior, Vail brings in Dr. Molly Arrington (Frances McDormand), a respected neuropsychologist, to evaluate Aaron’s mental state. Her role is to assess whether he was psychologically capable of understanding or controlling his actions at the time of the crime. After conducting a series of interviews and psychological tests, Dr. Arrington’s testimony introduces complex psychological concepts to the jury and becomes a turning point in the defense’s strategy. Her appearance marks the second and more prominent use of expert testimony in the film, shifting the courtroom narrative from physical evidence to questions of mental health and legal responsibility. 

VAIL: Dr. Arrington, how much time have you spent with Aaron Stampler? 

ARRINGTON: Approximately sixty hours. 

VAIL: During that time, did he ever experience—did you ever witness what is medically referred to as a fugue state—or blackout? 

ARRINGTON: Yes. 

VAIL: On how many occasions? 

ARRINGTON: Two, I believe. 

VAIL: Now, are you talking about light-headedness or fainting spells of the variety most of us have experienced at one time or another? 

ARRINGTON: No, I’m speaking of the kind that almost always accompanies schizophrenia or MPD. 

VAIL: Can you explain MPD? 

ARRINGTON: Multiple Personality Disorder. 

VENABLE: Objection, Your Honor— 

VAIL: Dr. Arrington is merely stating what she personally observed— 

Medical expert witnesses frequently serve a dual role in legal proceedings, as both fact and expert witnesses. In their fact witness capacity, they provide testimony based on firsthand involvement in a case, such as treating a patient or reviewing medical records. As expert witnesses, they offer specialized opinions drawn from their medical training and experience. This dual function requires careful navigation, particularly in distinguishing between what was directly observed and what is concluded through expertise. 

VENABLE: Your Honor, I request a sidebar. 

She brushes past Vail on her way to the bench. Vail follows and joins her for a sidebar with [Judge] Shoat. 

VENABLE: Your Honor—if he wants to question his client’s sanity, I’d be happy to let him if he changes his plea from Not Guilty to Guilty by Reason of Insanity. 

VAIL: My plea remains Not Guilty. 

VENABLE: Fine. Not Guilty means what it says, Your Honor. Mr. Vail should not be allowed to discuss mental disorders of any kind. 

SHOAT: She’s absolutely right, Vail, you can’t have it both ways. 

VAIL: Your Honor, I am merely trying to establish a medical foundation for blackouts. 

VENABLE: That’s not what he’s doing. He’s saying the defendant is mentally unbalanced. 

VAIL: No, I’m not. Again, Your Honor, I ‘m attempting to prove the defendant suffers from blackouts—seizures of unconsciousness. 

In many jurisdictions, an attorney can’t simultaneously maintain a “not guilty” plea and argue that the defendant lacked criminal responsibility due to insanity without formally entering an alternative or conditional insanity plea. That usually requires notifying the court and opposing counsel, since it triggers specific procedural safeguards, expert evaluations, and jury instructions. 

Vail is threading the needle in trying to introduce medical evidence (like blackouts) that suggest diminished capacity without fully invoking an insanity defense. Venable calls that out, arguing it’s a backdoor attempt to sway the jury on mental fitness without following the formal requirements. 

Shoat studies him. 

SHOAT: I’ll allow you to continue if you tread very, very carefully with this witness. 

VAIL: Thank you, Your Honor. 

They come away from the bench, Venable going to her table and whispers something to an assistant. Vail returns to the examining lectern. 

VAIL: Dr. Arrington, without mentioning the medical condition you previously referred to can you tell me—what are some of the causes of blackouts? 

ARRINGTON: There are many, but I’m not sure how much I can elaborate within these legal restrictions. 

This catches Dr. Arrington off guard. Trial strategies are subject to very sudden shifts; it is best to follow your attorney’s lead—even if you aren’t sure where they’re going.  

VAIL: Let’s try approaching it this way. Did the defendant, in his conversations with you, ever discuss his father? 

ARRINGTON: Yes, he did. His father worked in a Kentucky coal mine. The “black hole” as Aaron calls it. He also beat Aaron on many occasions. 

VAIL: Did Aaron say how his father died? 

ARRINGTON: Yes. It was a mining accident. 

VAIL: What about Aaron’s mother? Did he discuss her with you? 

ARRINGTON: Yes. She spent the last several years of her life in an asylum in Morgan City, Kentucky. 

VAIL: Why? 

ARRINGTON: She was diagnosed—can I say it? 

VAIL: Well, you’re speaking about her, and it’s a matter of record— (more to Shoat)— so I don’t see why not. 

ARRINGTON: She was schizophrenic. 

Vail glances at Shoat, who allows it with a slight negative shake of her head. 

The gambit has paid off—at least up to this point. Sometimes, a trial strategy is employed where what the jury knows implicitly is more important than what is said. The jury has already heard that MPD can produce blackouts, and now has heard that Aaron’s mother was schizophrenic. Vail doesn’t need to connect the dots for the jury, although she will try. 

VAIL: Could constant beatings, a mother’s mental instability and a violent family death produce, in your opinion, disorientation in a 15-year-old—any 15-year-old. 

VENABLE: Objection, Your Honor. 

SHOAT: Too close for comfort, Mr. Vail. Sustained. 

This time it didn’t pay off. If a jury hears testimony or evidence that is ruled inadmissible, the judge will typically instruct the jury to disregard it. On the other hand, the content can be so prejudicial that it’s unrealistic to expect the jurors to truly “forget” it. This is often rendered “you can’t unring the bell”. In these cases, there can be a mistrial caused by incurable prejudice. Fortunately for Vail, Judge Shoat is fairly patient.  

VAIL: (to Arrington) Is it possible—rather I should say, could a reasonable medical assumption be made—that Archbishop Rushman was murdered while the defendant—for whatever reason—was blacked out? 

VENABLE: Objection 

VAIL: I didn’t say anything that hasn’t already been said. 

SHOAT: overruled. 

ARRINGTON: Medically that is possible, yes. 

Dr. Arrington is avoiding absolutes, and giving her expert medical opinion. 

VAIL: Is it also possible that someone wielding a knife and attacking the Archbishop could have been the actual trigger for such a blackout? 

VENABLE: Objection 

SHOAT: Overruled. 

ARRINGTON: Yes. 

VAIL: In your opinion—and we realize it is your opinion—is Aaron Stampler capable of murder? 

ARRINGTON: No. Aaron is too timid to express normal anger and frustration. He keeps these emotions repressed which is why his psyche has splintered and created an entirely separate personality that is. 

VENABLE: Your Honor— 

VAIL: I didn’t say it— 

SHOAT: The jury will disregard the last statement from this witness, as will the court. Mr. Vail—I remind you that you’ve been warned. Twice now. Do you really want to pursue this line of questioning? I suggest you think long and hard before you answer. 

VAIL: No further questions, Your Honor. 

Vail was operating on the razor’s edge here, with the jury twice hearing disallowed testimony.  

SHOAT: Madam Prosecutor, do you wish to cross? 

VENABLE: You bet I do 

Venable approaches the lectern. 

VENABLE: Since you brought it up, against the instructions of the court, is multiple personality disorder your primary area of expertise? 

This is a legal gray area. On one hand, Arrington brought up MPD which typically opens the door to challenges. On the other, Judge Shoat had asked the jury to disregard that testimony. Vail might have objected, but had already pressed his luck as far as it would go.  

ARRINGTON: It’s not my primary field, no. 

VENABLE: Is forensic psychiatry your primary area of expertise? 

ARRINGTON: No, I’m a neuropsychologist. 

VENABLE: I see. So you have no forensic experience and you’re more of an academic? [Arrington nods, ceding the point] Then you will forgive this rather academic question. I’m driving, somebody cuts me off. I feel like killing this guy, but I don’t. Now do l? 

Here, Venable is impeaching Venable’s expertise as it pertains to the facts of the case. She doesn’t stay on the topic for long, spending just enough time to give the jury subtext—that she is a mere academic with no forensic experience. Differentiating an expert’s practical experience from academia is a common courtroom tactic.  

ARRINGTON: I would hope not. 

VENABLE: That’s right. Things happen to us. People wrong us. But we don’t all invent psychopaths to do our dirty work for us, doctor? 

ARRINGTON: I’m not suggesting you have multiple personalities. I’m saying Mr. Stampler does.  

VENABLE: Yes, I know. We heard. You have also testified that you have met this… What was his name again? 

Venable is still trying to have it both ways—reminding the court that they have heard evidence of MPD over objections and court admonishment, while addressing that excluded testimony to further her case.  

ARRINGTON: Roy. 

VENABLE: Roy what? 

ARRINGTON: He didn’t give a last name. 

VENABLE: I see. Did this Roy tell you that he had murdered the Archbishop? 

ARRINGTON: Mr. Vail was with him, I was outside, but soon after I was in the room and saw both Roy and his transformation back to Aaron. 

VENABLE: Did you happen to tape this appearance of Aaron…? Oh, I’m sorry. I just cannot get used to this name. 

Venable is playing games here, pretending to keep slipping up on Aaron’s second personality’s name “Roy”. Doing so in a mocking, eye-rolling manner is for the benefit of the jury.  

ARRINGTON: Roy. 

VENABLE: Did you? 

ARRINGTON: No, the tape was off. 

VENABLE: Off? So you have no record whatsoever of his appearance. 

ARRINGTON: No. 

While it is a viable strategy to remind the court that the tape was off, presumably implying there is a hearsay issue; under the mental condition exception to the hearsay rule the testimony is likely allowable.  

VENABLE: No. Does Aaron know right from wrong? 

ARRINGTON: Yes, he does. 

VENABLE: If Aaron butchered the Archbishop… 

VAIL: Objection. 

Unnecessarily inflammatory language may be objected to. This has the added benefit of interrupting Venable, but she continues, undeterred.  

VENABLE: would he know if Aaron murdered the Archbishop? Would he know he’d broken the law? 

ARRINGTON: Yes, he would. But it wasn’t Aaron… 

VENABLE: Oh, yes, I know, doctor. It was Roy. That’s all. No further questions, Your Honour. 

Venable’s cross-examination combined impeaching Arrington for lack of practical experience, making light of her conclusions, and questioning the evidentiary support for the transformation. Nevertheless, the last-ditch effort was for naught—the jury would go on to return a “not guilty by reason of insanity” (NGRI) verdict. 

This is a bit of Hollywood fiction—in reality, the NGRI verdict would probably require pleading as such, the jury would receive an NGRI instruction, and Vail would likely not have been able to repeatedly smuggle in disallowed testimony. 

Aftermath-Spoiler Alert! 

In a surprise twist, Venable’s questioning over faked MPD would turn out to be foreshadowing—Aaron was faking the condition all along. The film’s conclusion is ambiguous, but implies that he gets away with it. The film gets this correct, as double jeopardy attaches and would prevent a re-trial. While there is a new evidence exception, it only applies to convictions, not acquittals. Notably, this is not the case everywhere. In the UK new and compelling evidence (like a confession) may result in a retrial.   

Conclusion 

Be an Arrington, not a Woodside. Avoid absolutes whenever possible, answer questions truthfully—even when you perceive the answers to be bad news for your engaging attorney, and maintain a professional and confident demeanor throughout cross-examination.  

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