Friday, November 15, 2013

State v. Kelly case brief

State v. Kelly case brief summary
478 A.2d 364 (1984)

Defendant appealed from judgment of the New Jersey Superior Court, Appellate Division, which upheld defendant's conviction for reckless manslaughter.

Defendant was charged with murder after stabbing her husband. At trial, defendant attempted to argued that she suffered from battered spouse syndrome and that the stabbing was an act of self-defense. However, trial court excluded defendant's expert's testimony regarding battered spouse syndrome, regarding it as irrelevant. The jury subsequently found defendant guilty of reckless manslaughter. Defendant argued that the trial court erred in excluding her expert's testimony.

  • On appeal, the court first held that evidence relating to battered spouse syndrome was relevant in determining whether a reasonable fear of danger existed requisite to a self-defense claim. 
  • Thus, the court held that the trial court committed reversible error. 
  • However, examining the theory of battered spouse syndrome, as well as defendant's expert's record, the court held that the emerging nature of the syndrome's theory necessitated giving the trial court broad discretion in determining whether defendant's expert testimony was sufficiently reliable to be admissible.

Judgment vacated, and case remanded for a new trial, with instructions to reconsider admitting testimony of defendant's expert witness.

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