State v. Kelly

Supreme Court of New Jersey · 1984 · Criminal Law

Criminal LawSelf-DefenseExpert TestimonyBattered-Woman's Syndromeself-defensebattered-woman's syndromeexpert testimonyscientific reliability

Facts

Gladys Kelly stabbed her husband Ernest with scissors and claimed she acted in self-defense after years of repeated beatings and threats by him. According to her version, on the day of the homicide he assaulted her in public, choked her, hit her, bit her, and then ran toward her again moments later, causing her to fear he would kill her. To support the mental-state component of self-defense, she offered Dr. Lois Veronen to testify about battered-woman's syndrome, to explain the effects of prolonged abuse and why Kelly remained in the relationship. The trial court excluded that testimony as inadmissible on the self-defense issue.

Issue

Whether expert testimony on battered-woman's syndrome is admissible in a homicide prosecution to assist the jury in evaluating a defendant's claim of self-defense. More specifically, the question was whether such testimony was relevant to the honesty and reasonableness of defendant's belief that deadly force was necessary, and whether it satisfied New Jersey's standards for expert scientific evidence.

Rule

Under New Jersey law, expert testimony is admissible when it concerns a subject beyond the ken of the average juror, the field is sufficiently reliable under accepted scientific standards, and the witness is sufficiently qualified. In a self-defense case, expert testimony on battered-woman's syndrome may be admitted, if those standards are met, to help the jury evaluate the honesty and objective reasonableness of the defendant's belief that deadly force was immediately necessary to protect against death or serious bodily harm. The expert may explain the syndrome and relate its characteristics to the defendant, but may not opine directly that the defendant's belief on the day of the killing was reasonable.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Newark, Dana Morales is charged with homicide after fatally stabbing her live-in partner during a street argument. She claims years of repeated abuse made her believe he was about to kill her, and she offers a clinical psychologist to explain battered-woman's syndrome, including why abused partners often remain in violent relationships and how that history can affect perception of danger.

Should the trial court admit the testimony if the psychologist is qualified and the field is shown sufficiently reliable?

Explanation. The majority held that battered-woman's-syndrome testimony may be relevant in a self-defense case to help the jury assess both whether the defendant honestly believed deadly force was necessary and whether that belief was objectively reasonable, so long as expert-testimony requirements are met. The testimony is helpful because myths about why abused partners stay may otherwise distort jurors' assessment of fear and credibility.