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Supreme Court of New Jersey - 478 A.2d 364, 97 N.J. 178
Tags: Criminal law, Self-defense, Justification
The case involves Gladys Kelly, who was convicted of reckless manslaughter for stabbing her abusive husband, Ernest. The trial court excluded her expert testimony on battered-woman's syndrome, but the Supreme Court of New Jersey reversed the decision, holding that the syndrome is an appropriate subject for expert testimony. The court found that Ms. Kelly's expert was qualified and that her testimony on the syndrome should be admitted as relevant to the defendant's belief that deadly force was necessary to protect herself against death or serious bodily harm. Ms. Kelly's appeal challenges several aspects of the trial and her sentence, including the exclusion of expert testimony on the syndrome, an erroneous charge on provocation, and the exclusion of testimony about Mr. Kelly's sexual assault of one of Ms. Kelly's daughters. The case highlights the institutionalized bias against battered women in law enforcement agencies. Dr. Veronen testified that Gladys Kelly suffered from the battered-woman's syndrome and was a victim of domestic violence. The admissibility of expert testimony on the syndrome depends on its relevance to Kelly's claim of self-defense and whether it meets the standards for admission of expert testimony in the state. Expert testimony on battered-woman's syndrome is admissible to show the defendant's honest belief that she was in imminent danger of death and to aid in determining the objective reasonableness of her belief. The expert can explain the common characteristics of a battered wife, such as learned helplessness, lack of options, fear of more abuse, belief in the husband's power, and hope for change. Expert testimony is crucial in correcting misconceptions and common myths about battered women.
The court allows expert testimony on the "battered women's syndrome" for self-defense, which is a valid psychological condition resulting from long-term abuse causing psychological numbness and cyclical behavior. Evidence of the decedent's sexual assaults on the defendant's daughter is admissible. Admissibility of expert testimony on the syndrome in criminal trials is determined by Evidence Rule 56(2), which requires the intended testimony to concern a subject matter beyond the average juror's knowledge, be reliable, and the witness to have sufficient expertise. The reliability of expert testimony can be established through the testimony of knowledgeable experts, authoritative scientific literature, or persuasive judicial decisions that acknowledge the general acceptance of expert testimony. The syndrome has been recognized as a scientifically valid doctrine within the professional community, supported by expert testimony and authoritative literature.
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