AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The case involves two separate criminal prosecutions in which the accused were charged with sexual offenses. In one case, the complainant, a 15-year-old, alleged rape by an acquaintance, while in the other, a 17-year-old alleged long-term sexual abuse by her stepfather. Expert testimony regarding post-traumatic stress disorder (PTSD) was introduced in both cases to support the claims of sexual abuse (paras 6-7, 12-13).

Procedural History

• Trial Court (Alberico): Convicted the accused of criminal sexual penetration and kidnapping, admitting expert testimony on PTSD (paras 3, 9).
• Trial Court (Marquez): Convicted the accused of criminal sexual penetration, admitting expert testimony on PTSD (paras 3, 17).
• Court of Appeals (Alberico): Reversed the conviction, holding that the trial court erred in admitting PTSD testimony to prove sexual abuse (paras 3, 28-29).
• Court of Appeals (Marquez): Reversed the conviction, relying on its reasoning in Alberico (paras 3, 5).

Parties' Submissions

• State: Argued that PTSD is a scientifically valid and generally accepted diagnosis, capable of pinpointing the cause of symptoms, and that expert testimony would assist the jury in understanding the evidence. The State also advocated abandoning the Frye test in favor of the Rules of Evidence (paras 26-27).
• Defendants: Contended that PTSD evidence lacked a proper scientific foundation, was not relevant to proving sexual abuse, and improperly bolstered the complainants' credibility, thereby prejudicing the defendants. They also argued for the continued application of the Frye test (paras 23-24).
• Amicus (New Mexico Criminal Defense Lawyers Association): Supported the defendants, emphasizing the need for the Frye test and arguing that PTSD is not a reliable forensic tool for determining the cause of symptoms (para 25).

Legal Issues

• Whether expert testimony on PTSD is admissible to establish that a complainant was sexually abused (paras 1, 4).
• Whether the Frye test should be abandoned in favor of the Rules of Evidence for determining the admissibility of scientific evidence (paras 1, 27).
• Whether expert testimony on PTSD improperly encroaches on the jury's role by bolstering the complainant's credibility (paras 24, 84).

Disposition

• Alberico: The Supreme Court of New Mexico reversed the Court of Appeals' decision and reinstated the conviction (para 103).
• Marquez: The Supreme Court of New Mexico affirmed the Court of Appeals' decision to reverse the conviction but on different grounds, remanding the case for a new trial (para 104).

Reasons

Per Frost J. (Baca and Franchini JJ. concurring):

• Admissibility of PTSD Testimony: The Court held that PTSD is grounded in valid scientific principles and is generally accepted in the psychological community. PTSD evidence is probative and assists the jury in understanding whether a complainant's symptoms are consistent with sexual abuse (paras 73-76).
• Abandonment of Frye Test: The Court abandoned the Frye test, finding it outdated and inconsistent with the Rules of Evidence. Instead, the Court emphasized that the admissibility of scientific evidence should focus on its validity and reliability under Rule 702 (paras 46-47, 99).
• Limitations on Expert Testimony: The Court ruled that experts may testify about whether a complainant's symptoms are consistent with sexual abuse but may not opine on the complainant's credibility or identify the accused as the perpetrator. Such testimony improperly invades the jury's role (paras 84-89).
• Application to Alberico: The expert testimony in Alberico was properly limited to whether the complainant's symptoms were consistent with sexual abuse, and the trial court did not abuse its discretion in admitting it (para 93).
• Application to Marquez: The expert testimony in Marquez improperly addressed the complainant's credibility and identified the accused as the perpetrator, which constituted reversible error. The case was remanded for a new trial (paras 94-95).