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 Defendant was convicted of two counts of criminal sexual penetration and one count of kidnapping involving a 15-year-old complainant. The Defendant admitted to intercourse but claimed it was consensual. The complainant alleged that the Defendant forced her into non-consensual sexual acts after offering her a ride, driving her to a remote area, and later returning to Santa Fe, where she escaped. The complainant's testimony was corroborated by witnesses, medical evidence, and psychological testimony regarding her post-incident trauma (paras 2-4).
Procedural History
- District Court, Santa Fe County: The Defendant was convicted of two counts of criminal sexual penetration and one count of kidnapping.
Parties' Submissions
- Defendant-Appellant: Argued that the expert testimony of a psychologist diagnosing the complainant with post-traumatic stress disorder (PTSD) was inadmissible due to insufficient scientific reliability to determine whether a rape occurred (paras 6-7).
- Plaintiff-Appellee: Contended that the expert testimony was admissible to demonstrate the complainant's psychological condition and its consistency with sexual assault trauma (paras 6, 10).
Legal Issues
- Was the expert testimony diagnosing the complainant with PTSD admissible to support the inference that a rape occurred?
Disposition
- The Court of Appeals reversed the Defendant's conviction and remanded the case for a new trial (para 37).
Reasons
Per Hartz J. (Chavez J. concurring):
The Court held that the expert testimony diagnosing the complainant with PTSD was inadmissible because it lacked scientific validation to determine whether a rape occurred. The Court emphasized that while PTSD is a recognized diagnosis, it was developed as a therapeutic tool, not as a means to establish the truth of past events. The testimony risked misleading the jury by suggesting that the psychologist could determine the veracity of the complainant's account, which is beyond the scope of scientific reliability (paras 19-27).
The Court further noted that the testimony's purpose was to infer that the complainant's psychological condition indicated a severe trauma, such as rape, but no independent validation supported this method. The Court concluded that admitting such testimony violated Rule 11-702 of the New Mexico Rules of Evidence, which requires expert testimony to assist the trier of fact without misleading or confusing it (paras 28-33).
Bivins J., dissenting:
Judge Bivins dissented, arguing that the trial court did not abuse its discretion in admitting the expert testimony. He contended that the testimony was limited to diagnosing PTSD and stating that the complainant's symptoms were consistent with sexual assault, without asserting that a rape definitively occurred. He likened this to medical testimony in personal injury cases, where experts opine on injuries consistent with specific causes. Bivins emphasized that such testimony could assist the jury in understanding the complainant's behavior and symptoms, which are outside the knowledge of laypersons (paras 39-54).