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Expert testimony regarding the battered woman syndrome can be admitted to help the jury not only to understand the battered woman syndrome but also to determine whether the defendant had reasonable grounds for an honest belief that she was in imminent danger when considering the issue of self-defense. Expert testimony on the battered woman syndrome helps dispel the ordinary lay person's perception that a woman in a battering relationship is free to leave at any time.
Defendant Barbara Bonner, who had stabbed her husband, was convicted of manslaughter, a violation of § 13A-6-3, Code of Alabama 1975. During the trial of the case, the defense intended to proffer an expert testimony concerning the "battered women syndrome." The defense counsel informed the trial court that the expert was a social worker who had a master’s degree and who regularly counseled battered women. Defense counsel further stated, in an offer of proof, that although the expert had never counseled the defendant, he was not offering the expert's testimony to show that the defendant suffered from any syndrome but rather to show the "psychological coping mechanisms of battered women and why they don't leave home and how they try to protect themselves." The trial court found that the relevance and materiality of the proffered testimony failed to outweigh its prejudicial effect on the jury. On appeal, the defendant contended that the trial court committed reversible error in refusing to allow her to introduce expert testimony concerning the "battered women syndrome."
Did the trial court err in refusing to allow defendant’s introduction of expert testimony concerning the "battered women syndrome?"
The Court found that the evidence supported defendant's claim that she had been severely abused during the marriage. The Court held that, under such circumstances, expert testimony was admissible to show that defendant reasonably believed it was necessary to use deadly force to prevent imminent death or great bodily harm. The Court noted that expert testimony on the battered woman syndrome should not be categorized as an attempt to establish diminished capacity or lack of responsibility but, instead, dealt with the issue of reasonableness. Accordingly, the Court reversed the conviction and remanded.