Quick Summary
Felomino Batangan (defendant) was charged with sexually abusing his daughter (complainant). At trial, an expert witness testified implicitly on the complainant’s credibility. The issue centered on whether such testimony was admissible under Evidence Law.
The Supreme Court of Hawaii vacated Batangan’s conviction due to the prejudicial nature of the expert witness testimony, which did not assist the jury as required by law.
Facts of the Case
Felomino Batangan (defendant) faced charges of sexually abusing his daughter, the complainant, when she was six or seven years old. The complainant’s allegations lacked specificity regarding dates and details, and no physical evidence or witnesses corroborated the abuse.
Initially, the complainant reported physical abuse to school officials and later recanted, only to accuse Batangan of sexual abuse. Subsequently, she retracted her sexual abuse allegations but testified to them at trial.
The State introduced Dr. John Bond as an expert witness in clinical psychology specializing in sexually abused children. He evaluated the complainant and implicitly testified to her credibility and the occurrence of abuse by Batangan, leading to Batangan’s conviction for first degree sexual abuse.
Procedural Posture and History
- Felomino Batangan was indicted on charges of second-degree rape and first-degree sexual abuse.
- In the first trial, Batangan was acquitted of rape, but a hung jury led to a mistrial on the sexual abuse charge.
- The State retried Batangan on the sexual abuse charge.
- Dr. John Bond’s expert testimony was admitted under State v. Kim, despite objections from the defense.
- Batangan was convicted of first-degree sexual abuse and appealed the decision based on the admission of Dr. Bond’s testimony.
I.R.A.C. Format
Issue
Whether the trial court erred in admitting expert witness testimony that implicitly asserted the credibility of the child complainant in a case of alleged sexual abuse.
Rule of Law
Expert testimony is admissible if it assists the trier of fact to understand evidence or determine a fact at issue, and may not usurp the jury’s role in assessing witness credibility or deciding the case.
Reasoning and Analysis
The Supreme Court of Hawaii acknowledged the difficulty in prosecuting child sexual abuse cases due to the lack of eyewitnesses and physical evidence. However, it emphasized that expert testimony must assist the jury without unduly prejudicing the defendant.
The court found that Dr. Bond’s testimony did not significantly contribute to understanding unique behaviors associated with child sexual abuse victims and instead gave an implicit opinion on the complainant’s credibility.
The court concluded that this testimony did not meet the criteria for admissibility under Hawaii Rules of Evidence Rule 702 and thus prejudiced Batangan’s defense. The court overruled any inconsistent holding from State v. Kim that allowed for expert opinions on witness credibility in child sexual abuse cases.
Conclusion
The Supreme Court of Hawaii vacated Batangan’s conviction and remanded for a new trial, ruling that Dr. Bond’s testimony was impermissible and prejudicial under Hawaii Rules of Evidence Rule 702.
Key Takeaways
- Expert testimony must assist the jury in understanding evidence or determining facts without usurping their role in assessing credibility.
- Testimony that implies a witness’s credibility is not admissible because it invades the province of the jury.
- The Supreme Court of Hawaii overruled previous decisions that permitted expert opinions on witness credibility in child sexual abuse cases, aligning with evidentiary rules that protect defendants’ right to a fair trial.
Relevant FAQs of this case
References
Was this case brief helpful?