holding that it was error for the trial court to admit expert testimony on "rape trauma syndrome” to prove that a victim had been raped, stating that "[r]ape trauma syndrome is not the type of scientific test that accurately and reliably determines whether a rape has occurred” and that the “scientific evaluation of rape trauma syndrome has not reached a level of reliability that surpasses the quality of common sense evaluation present in jury deliberations”
How later courts described this case
- holding that it was error for the trial court to admit expert testimony on "rape trauma syndrome” to prove that a victim had been raped, stating that "[r]ape trauma syndrome is not the type of scientific test that accurately and reliably determines whether a rape has occurred” and that the “scientific evaluation of rape trauma syndrome has not reached a level of reliability that surpasses the quality of common sense evaluation present in jury deliberations”
- holding that expert’s conclusion that victim was “raped” was a legal conclusion which was of no use to the jury and explaining that “opinions involving a legal analysis or mixed questions of law and fact are deemed to be of no use to the jury”
- holding that it was reversible error to allow opinion testimony from a sexual assault counselor on whether the victim had "typical post-rape symptoms and behavior of rape victims" and on whether the victim was telling the truth
- stating that expert opinions concerning a witness’s capacity to perceive the world around him or her “are generally inadmissible because such opinions invade the jury’s province to make credibility determinations.”
Written by the judges who cited it.
Distinguished
Distinguished by State v. Edwards, 2006 Minn. LEXIS 430 (2006)
The state concedes that the question was “perhaps inartfully phrased” but argues that Chambers, Provost, and Saldana are inapposite because James’s use of the word “intent” did not refer to his legal opinion on mens rea, but rather his factual opinion as to whether the bullets were likely to hit the vehicle’s occupants.
Distinguished by State v. Bachman, 1989 S.D. LEXIS 157 (1989)
Again, we believe that Saldana is factually inapposite.
The opinion
PETERSON, Justice
(concurring specially)-
I concur in the result, based upon the impermissible testimony of Ms. Dreyer that the victim had not fantasized or fabricated her story, and in overruling State v. Cox, 172 Minn. 226 , 215 N.W. 189 (1927), to the extent it would approve such testimony.
WAHL, J., took no part in the consideration or decision of this case.