Bechtel v. State
840 P.2d 1 (1992)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Expert testimony on Battered Woman Syndrome is admissible to aid a jury in understanding the reasonableness and imminence elements of a self-defense claim. The reasonableness of a battered woman's belief that she is in imminent danger of death or great bodily harm is to be evaluated from the perspective of a reasonable person in the circumstances and from the viewpoint of the defendant.
Facts:
- Donna Lee Bechtel met Ken Bechtel in June 1981 and they married on August 25, 1982.
- The first instance of violence occurred on July 4, 1982, when an intoxicated Ken Bechtel threw Donna into a boat's windshield and later slammed her head into a car window.
- Over the next two years, Ken Bechtel subjected Donna to approximately 23 battering incidents, which typically occurred when he was intoxicated and involved him pounding her head against objects and threatening her.
- Donna Bechtel sought emergency room treatment on three occasions and police assistance on five occasions, but the abuse continued.
- On September 23, 1984, Ken Bechtel returned home highly intoxicated, awakened Donna, and ordered her to drink with him.
- Later that day, he followed her to the bedroom, pulled her by the hair, sexually assaulted her, and repeatedly banged her head against the headboard until he slumped on top of her.
- After Donna managed to free herself and went to the bathroom, Ken followed her and continued the assault.
- Shortly thereafter, as she sat on the floor, she heard a gurgling sound, saw Ken with a contorted look and his arms raised, reached for a gun under the bed, and shot him.
Procedural Posture:
- Donna Lee Bechtel was initially tried and convicted of Murder in the First Degree in the District Court of Oklahoma County.
- The Oklahoma Court of Criminal Appeals reversed that conviction and remanded the case for a new trial.
- Upon retrial in the District Court of Oklahoma County, a jury again found Bechtel guilty of Murder in the First Degree and set punishment at life imprisonment.
- The trial court entered a judgment and sentence in accordance with the jury's verdict.
- Donna Lee Bechtel (Appellant) perfected an appeal from this second conviction to the Oklahoma Court of Criminal Appeals.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court commit reversible error by refusing to admit expert testimony on Battered Woman Syndrome to help a jury determine the reasonableness and imminence elements of a self-defense claim asserted by a defendant with a history of being abused?
Opinions:
Majority - Johnson, J.
Yes, the trial court commits reversible error by refusing to admit expert testimony on Battered Woman Syndrome (BWS). Such testimony is necessary to help the jury understand the reasonableness of the defendant's belief that she was in imminent danger, as BWS is a substantially scientifically accepted theory that can counter common misconceptions about victims of domestic violence. The court reasoned that BWS testimony explains how a history of abuse can heighten a victim's sensitivity to danger, making her perception of an imminent threat reasonable from her subjective viewpoint. The court also held that the trial court erred by misapplying the hearsay rule to exclude the victim's threatening statements and by failing to properly instruct the jury that the State bears the burden of disproving self-defense beyond a reasonable doubt.
Dissenting - Lumpkin, V.P.J.
No, the trial court did not commit error. The facts of this case present a traditional self-defense claim, not one requiring the adoption of Battered Woman Syndrome. The majority is abdicating the rules of appellate review to embrace a sociological theory not supported by the evidentiary record. If such a theory were to be considered, the court should adopt the gender-neutral and more scientifically accepted diagnosis of Post-traumatic Stress Disorder (PTSD) rather than the gender-specific BWS. The majority's opinion creates confusion regarding the established legal principles of imminence and hearsay, and oversteps the court's role by creating new law where the legislature has already acted.
Concurring - Parks, J.
Yes, the trial court erred, but the majority's reasoning is overly broad. Expert testimony on Battered Woman Syndrome was relevant and should have been admitted to assist the jury in assessing the reasonableness of the appellant's self-defense claim from her specific viewpoint, a concept already well-established in Oklahoma law. However, the majority's decision to radically overhaul the laws of self-defense and create new jury instructions was unnecessary and creates confusion. The error requiring reversal was the exclusion of the expert testimony and the failure to properly instruct the jury on the State's burden of proof regarding self-defense.
Analysis:
This landmark case established the admissibility of expert testimony on Battered Woman Syndrome in Oklahoma, significantly altering how self-defense claims by victims of domestic abuse are evaluated. It shifts the legal standard for reasonableness toward a more subjective inquiry, requiring the jury to consider the defendant's unique experiences and perceptions shaped by a history of abuse. The decision re-contextualizes the concept of 'imminence,' recognizing that for a battered woman, the threat of deadly violence can be persistent and ever-present. This precedent forces courts to move beyond traditional self-defense paradigms, which are often based on confrontations between strangers, and to apply a framework that better reflects the psychological realities of long-term domestic violence.
Unlock the full brief for Bechtel v. State