Can a lay witness testify in the form of an opinion?

Rule 701 permits a lay witnessi.e., one not testifying as an expertto testify "in the form of an opinion." But as Rule 701(b) provides, such opinion testimony is admissible only if it is "helpful to clearly understanding the witness's testimony or to determining a fact in issue."⁶⁸ As we explained in Hester v. BIC Corp., Rule 701(b) helps to protect "against the admission of opinions which would merely tell the jury what result to reach, " rather than providing information that would assist the jury in drawing its own conclusions.⁶⁹ In employment discrimination actions, "Rule 701(b) bars lay opinion testimony that amounts to a naked speculation concerning the motivation for a defendant's adverse employment decision."⁷⁰ Although witnesses may testify regarding "their own observations of the defendant's interactions with the plaintiff or with other employees," they may not opine as to the motives, racial or otherwise, underlying those interactions.⁷¹