State v. Batangan case brief

State v. Batangan case brief

71 Haw. 552, 799 P.2d 48, 1990 Haw.

CASE SYNOPSIS: Defendant sought review of the judgment from the First Circuit Court (Hawaii), which allowed expert testimony that was objected to by defendant and convicted defendant of first degree sexual abuse.

FACTS: Defendant was accused of having sexual contact with the complainant, his daughter. The state presented an expert witness who testified regarding his evaluation of the complainant. The testimony included the expert's opinion that the complainant was believable in her accusations. Defendant objected to the testimony, but the trial court determined that it was admissible. Defendant was found guilty of first degree sexual abuse, but on appeal, the court vacated the judgment and remanded for a new trial.

ANALYSIS:

The court determined that the expert's testimony was inadmissible under Haw. R. Evid. 702 and that it was prejudicial to defendant. Although the expert was qualified, the testimony that he provided regarding the behavior of a sexually abused child was a minor part of the case; however, the expert did impermissibly leave the jury with the indication that the accusations by the complainant were truthful and believable.

CONCLUSION: The court vacated the judgment of the trial court convicting defendant of first degree sexual assault and remanded the case for a new trial.

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