New Jersey v. Kelly
478 A.2d 364
Brief Filed: 4/83
Court: Supreme Court of the State of New Jersey
Year of Decision: 1984
Read the full-text amicus brief (PDF, 659KB)
Whether expert testimony on battered women's syndrome is admissible to help establish claims of self-defense in a murder case — parallels case of Hawthorne v. Florida, 470 So.2d 770 (1985)
Battered Women's Syndrome; Expert Witnesses/Psychologists' Competency
A victim of spouse abuse was charged with murder for the death of her husband. At trial, defense counsel sought to have the testimony of a clinical psychologist admitted on the question of the defendant's claim of self-defense. The trial court denied admission of the evidence on the ground that the testimony was inadmissible under the New Jersey standard of self-defense. The New Jersey appellate court affirmed the conviction for reckless manslaughter and ruled that exclusion of the expert testimony was harmless error in light of evidence of appellant's guilt and the fact that evidence of her prior history of abuse had been liberally admitted at trial. The New Jersey Supreme Court granted review of the case.
APA's amicus brief argued that: 1) the requirement that expert testimony must be reliable calls for proof that the expert's methodology is generally accepted by the relevant scientific community; it does not require proof that the expert opinion be unanimous or that the expert's methodology is infallible; and (2) the methodology used by psychologists studying battered women is generally accepted by the relevant scientific community and, accordingly, the state of scientific knowledge supports a reliable expert opinion on battered women's syndrome.
The New Jersey Supreme Court held that expert testimony concerning battered women's syndrome was relevant to prove the honesty and reasonableness of the defendant's belief that deadly force was necessary to protect herself from serious harm and, therefore, support her self defense claim; and that such testimony satisfied the criteria governing the admissibility of expert testimony. The Court reversed the defendant's conviction and ordered a new trial.