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Law School Case Brief

Ibn-Tamas v. United States - 407 A.2d 626 (D.C. 1979)

Rule:

Although a trial court's ruling to exclude expert testimony is reversible only for abuse of discretion, for being manifestly erroneous, there is an important trade-off for giving the trial court such latitude: that court must take no shortcuts; it must exercise its discretion with reference to all the necessary criteria. Otherwise, the very reason for such deference i.e., the trial court's opportunity to observe, hear, and otherwise evaluate the witness, will be compromised. Thus, the appellate court must not affirm a ruling premised on trial court discretion unless the record clearly manifests either (1) that the trial court has ruled on each essential criterion, or (2) that the trial court, as a matter of law, had but one option.

Facts:

In September 1972, Dr. Yusef Ibn-Tamas and his wife, appellant Beverly Ibn-Tamas, got married. The marriage was marred by recurring violent episodes separated by periods of relative harmony. It was alleged that throughout their marriage, Dr. Ibn-Tamas repeatedly hurt his wife physically. On the morning of February 23, 1976, after a violent fight, Mrs. Ibn-Tamas shot and killed her husband. She was charged with second-degree murder while armed, and second-degree murder. At trial, the expert testimony offered by a certain Dr. Walker on the subject of battered women was considered to be inadmissible as evidence. Subsequently, Mrs. Ibn-Tamas was convicted. On appeal, she asserted that the trial court erred in excluding the expert testimony offered on the subject of battered women.

Issue:

Did the trial court err in ruling that Dr. Walker's testimony is inadmissible as evidence?

Answer:

The court did not make a determination.

Conclusion:

The appellate court remanded the case for a determination of the admissibility of expert testimony on the subject of battered women. The court found that the expert was not expressing an opinion on the ultimate question of whether appellant actually and reasonably believed she was in danger when she shot her husband and that the testimony would have assisted the jury in assessing appellant's credibility. Therefore, the court was unable to determine whether the expert's credentials were sufficient for the type of psychological testimony proffered or whether the state of scientific knowledge was sufficient to permit an expert witness.

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