United States v. Sharon Ann Rahm

Court of Appeals for the Ninth Circuit
93 Cal. Daily Op. Serv. 3431, 993 F.2d 1405, 93 Daily Journal DAR 5940 (1993)

ELI5:

Rule of Law:

Under Federal Rule of Evidence 702, expert psychological testimony regarding a defendant's mental condition is admissible to negate the mens rea element of a crime if it will assist the trier of fact, even if the defendant does not have a formal mental disorder and the expert's opinion is not conclusive.

Facts:

On August 3, 1991, Sharon Ann Rahm attempted to purchase a three-dollar box of tea from the Canton Bazaar using a counterfeit $100 bill.
The store manager identified the bill as counterfeit and told Rahm there were problems with it.
Rahm remained at the store for approximately fifteen minutes, waiting for her change or the return of the bill.
Rahm told the manager that she had received the $100 bill from a bank a few days prior.
At the time of the attempted purchase, Rahm had twenty-five dollars in genuine currency in her possession but did not offer to use it.
Upon her arrest, police officers searched Rahm's purse and found ninety-eight additional counterfeit $100 bills.
Rahm later provided a written statement to a Secret Service agent claiming she had found the ninety-nine bills at a bus stop and believed they were real.

Procedural Posture:

The government filed a pretrial motion in limine in the U.S. District Court (trial court) to exclude the expert testimony of psychologist Dr. Arvalea Nelson.
The district court granted the government's motion, ruling the testimony inadmissible.
After a jury trial, Sharon Ann Rahm was convicted of possession of counterfeit currency and attempting to pass counterfeit currency.
Rahm (appellant) appealed her conviction to the United States Court of Appeals for the Ninth Circuit, with the United States as the appellee.

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Issue:

Does a district court abuse its discretion under Federal Rule of Evidence 702 by excluding expert psychological testimony about a defendant's perceptual difficulties, offered to show she lacked knowledge that currency was counterfeit, on the grounds that she did not have a recognized mental disorder and the expert's opinion was not conclusive?

Opinions:

Majority - Reinhardt, J.

Yes. A district court abuses its discretion by excluding expert psychological testimony based on the erroneous legal premises that such testimony requires the defendant to have a formal mental disorder and that the expert's opinion must be conclusive. The proper inquiry under Fed. R. Evid. 702 is whether the specialized knowledge will assist the trier of fact in determining a fact in issue. The court reasoned that requiring a formal 'disorder' contradicts Fed. R. Crim. P. 12.2(b), which explicitly allows testimony on 'any other mental condition.' Furthermore, requiring a conclusive opinion imposes an unreasonably high standard, as experts often deal in probabilities, and the focus should be on the helpfulness of the underlying testimony, not the certainty of a final opinion. Applying the four-factor Amaral test, the court found Dr. Nelson's testimony was offered by a qualified expert on a proper subject (Rahm's perceptual difficulties relevant to the element of knowledge), was based on generally accepted tests (WAIS-R and MMPI), and its high probative value for Rahm's sole defense outweighed any potential prejudice.

Dissenting - Noonan, J.

No. The district court did not abuse its discretion, as the decision to admit expert testimony is a judgment call that should not be disturbed unless 'manifestly erroneous.' The trial judge reasonably concluded that the psychologist's testimony about Rahm's personality traits—being 'overhasty and unrealistic'—would not provide 'appreciable help' to the jury in deciding whether she knew the bills were counterfeit. Even if the exclusion was erroneous, the error was harmless because the circumstantial evidence of Rahm's guilt was overwhelming. Her possession of 98 additional counterfeit bills, her separation of fake and genuine currency, her lie to the store manager about the bill's origin, and the classic criminal method of using a large fake bill for a small purchase incontrovertibly established her knowledge, which the proposed testimony would not have explained away.

Analysis:

This decision significantly clarifies the standards for admitting expert psychological testimony related to a defendant's mens rea under FRE 702. By rejecting the requirement of a formal 'mental disorder,' the court broadens the scope of potentially admissible evidence to include a wider range of mental and cognitive conditions. The ruling also shifts the focus from the certainty of an expert's ultimate conclusion to the helpfulness of the underlying scientific evidence and analysis for the jury. This precedent makes it easier for defendants to introduce nuanced psychological evidence to challenge the prosecution's proof of specific intent or knowledge, impacting how such defenses are structured and presented in future criminal cases.

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