11th Circuit Upholds ER Physician's Testimony on the Bizarre

On plain error review, the Eleventh Circuit has upheld, in an unpublished opinion, the admissibility of a physician's testimony that the conduct of an ER patient (later to become a bank robbery defendant) was "a little bit bizarre." The physician also testified that although the defendant claimed in ER to have been struck in the head with the butt of a gun, he showed no evidence of edema or hematoma. See United States v. Dean, No. 06-14088 (11th Cir. Mar. 15, 2007) (Tjoflat, Hull, & Marcus, JJ.).