State v. Carter
762 So. 2d 662, 2000 WL 722189 (2000)
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Rule of Law:
An expert witness in a domestic violence case may testify that a defendant's history is consistent with that of a battered spouse and may opine on the defendant's state of mind, but may not offer an opinion on the ultimate issue of fact as to whether the defendant is a battered spouse, as this invades the province of the jury to determine witness credibility.
Facts:
- Yvonne Carter and Roger Scott were married and had two children together after a long, tumultuous relationship.
- Carter testified to a long history of severe physical, sexual, and mental abuse by Scott, which included him punching her, kicking her, threatening her with a gun, and giving her a venereal disease.
- On the night of November 21, 1993, Carter met Scott at the Bottom Line Lounge, where they began arguing.
- The argument continued outside, where Carter alleged Scott became violent, hitting her on the side of her face with keys and punching her.
- Carter claimed that Scott threatened to kill her, stated he was going to get another gun he owned, and walked to his truck.
- Believing Scott was reaching for a gun in a secret compartment in his truck's dashboard, Carter retrieved a gun from her purse and shot him once.
- Scott died from the single gunshot wound.
- Immediately after the shooting, Carter told police that Scott had been shot by an unknown man during a robbery attempt, a story she later admitted was false.
Procedural Posture:
- Yvonne M. Carter was charged by grand jury indictment with the second-degree murder of Roger Scott.
- Carter pleaded not guilty and was found competent to stand trial in a lunacy hearing.
- A twelve-person jury in the trial court found Carter guilty of the lesser-included offense of manslaughter.
- The trial court denied Carter's motion for a new trial and sentenced her to serve twenty-one years at hard labor, with sixteen years suspended and five years active probation.
- The trial court denied Carter's motion for reconsideration of sentence.
- Carter (as appellant) was granted a motion for appeal to the Court of Appeal of Louisiana, Fourth Circuit, against the State of Louisiana (as appellee).
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Issue:
In a homicide case where the defendant claims self-defense based on battered woman syndrome, does a trial court err by refusing to allow an expert witness to testify that the defendant meets the definition of a battered spouse?
Opinions:
Majority - McKay, Judge
No. The trial court did not err in prohibiting the expert from stating that the defendant was, in fact, a battered spouse. Permitting an expert to testify that the defendant was a battered spouse would be an impermissible opinion on the defendant's credibility and would usurp the jury's role as the sole finder of fact. The court reasoned that expert testimony should provide a scientific perspective to help the jury evaluate evidence for itself, not to directly state whether the defendant's claims of abuse are true. Citing State v. Foret, the court affirmed that an expert cannot opine on a witness's truthfulness. However, the trial court properly allowed the expert to testify that the defendant's history was 'consistent with' that of a battered spouse and that, in the expert's opinion, the defendant was in fear for her life on the night of the shooting. This approach provided the jury with the necessary context about domestic violence without improperly influencing its conclusion on the ultimate facts.
Analysis:
This case clarifies the permissible scope of expert testimony in cases involving battered woman syndrome in Louisiana. The court's decision reinforces the distinction between testimony that educates the jury on a specialized topic and testimony that offers a conclusion on an ultimate issue of fact or witness credibility. By allowing testimony that a defendant's history is 'consistent with' the syndrome but not that she 'is' a battered spouse, the ruling preserves the jury's fundamental role as the arbiter of facts. This precedent guides future cases by ensuring that expert testimony on domestic violence serves to explain the context of a defendant's actions and state of mind, rather than to definitively label the defendant, which remains the jury's prerogative.
