People v. Taylor
552 N.Y.S.2d 883, 552 N.E.2d 131, 75 N.Y.2d 277 (1990)
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Rule of Law:
Expert testimony on rape trauma syndrome is admissible for the limited purpose of explaining a complainant's behavior that might otherwise seem unusual or unbelievable to a lay jury, but it is not admissible as evidence to prove that a rape occurred.
Facts:
- Case 1 (People v. Taylor): A 19-year-old complainant was lured to a meeting spot, where a man she knew, John Taylor, got into her car at gunpoint.
- Taylor then directed her to a deserted beach where he raped and sodomized her.
- After the attack, the complainant initially told her mother and the police that she did not know who her attacker was.
- Approximately two hours later, while at the police station, the complainant identified Taylor as her attacker.
- Witnesses observed that the complainant appeared calm and controlled in the hours following the assault.
- Case 2 (People v. Banks): Ronnie Banks grabbed an 11-year-old girl who was playing with friends, pulled her into a garage, and sexually assaulted her.
- The next morning, the complainant told her grandmother about the assault.
- Following the incident, the complainant began suffering from nightmares, waking up in a cold sweat, developed a fear of returning to school, and started running away from home.
Procedural Posture:
- In People v. Taylor, the defendant's first trial in the trial court ended with a hung jury.
- At his second trial, the court admitted expert testimony on rape trauma syndrome, and a jury convicted Taylor of sodomy and attempted rape.
- Taylor, as appellant, appealed his conviction to the intermediate appellate court, the Appellate Division, which affirmed.
- In People v. Banks, the defendant was tried on multiple counts of sexual assault.
- The trial court admitted expert testimony on rape trauma syndrome, and a jury acquitted Banks of forcible counts but convicted him on statutory counts.
- Banks, as appellant, appealed his conviction to the intermediate appellate court, the Appellate Division, which affirmed.
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Issue:
Is expert testimony regarding rape trauma syndrome admissible to explain a complainant's behavior that might otherwise appear unusual to a lay jury, but inadmissible when offered solely to prove that a rape occurred?
Opinions:
Majority - Chief Judge Wachtler
Yes. Expert testimony on rape trauma syndrome is admissible for the limited purpose of explaining behaviors of a complainant that might seem counterintuitive to a jury, but it is not admissible to prove that the crime of rape was committed. The court reasoned that the scientific community has generally accepted that rape is a traumatic event that triggers identifiable symptoms in victims. Because many jurors hold common misconceptions about how a rape victim should behave (e.g., reporting immediately, appearing distraught), expert testimony can help clarify issues beyond the ken of the typical juror. In Taylor's case, the testimony was properly admitted to explain two such behaviors: the complainant's delay in identifying an attacker she knew and her calm demeanor after the assault. However, in Banks's case, the testimony was offered to show that the victim's symptoms were consistent with having been raped, which inescapably bears on proving the crime occurred. The court found this use to be improper, as its helpfulness is outweighed by the risk of undue prejudice to the defendant by creating an inference that the rape must have happened.
Analysis:
This decision establishes a crucial, purpose-based framework for the admissibility of psychological syndrome evidence in New York criminal law. It draws a clear distinction between using expert testimony as an educational tool to dispel juror myths and using it as substantive proof of the ultimate issue in a case. The ruling provides important guidance by limiting the scope of such testimony, thereby preventing experts from implicitly vouching for a complainant's credibility or usurping the jury's fact-finding role. This balancing act protects defendants from undue prejudice while allowing prosecutors to present relevant context for a complainant's behavior that might otherwise be misinterpreted.
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