State v. Kelly

Brief Fact Summary. The Defendant, Kelly (Defendant), stabbed to death her allegedly abusive husband. At her trial, the Defendant claimed self-defense and sought to call a psychiatric witness who would testify that she suffered from battered-woman’s syndrome.

Synopsis of Rule of Law. Expert testimony on battered-woman’s syndrome is relevant to the issue of a defendant’s state of mind at the time of the murder where there is evidence of a past history of abuse.

Facts. The Defendant was allegedly subject to violent beatings from her husband, sometimes as often as once a week, over the course of seven years of marriage. The day of the stabbing, her husband beat her up on the street after she asked for money to buy groceries. Passers-by separated them, but her husband subsequently caught up with her again. The Defendant, thinking her husband had come back to kill her, reached in her purse for a pair of scissors and stabbed him. At trial, she proffered the testimony of an expert witness who would state that her fear for her life was reasonable insomuch as she suffered from battered-woman’s syndrome. The trial court rejected the witness as irrelevant.

Issue. Was expert testimony that the Defendant was suffering from battered-woman’s syndrome at the time of the stabbing relevant to her state of mind?

Held. Yes. Remanded. The testimony of the expert witness would have shown that the Defendant suffered from battered-woman’s syndrome. Evidence of this affliction was relevant to the Defendant’s case insomuch as it arose out of a history of physical abuse from her husband and both explained why she had never left her husband and why her fear that her husband was going to kill her was reasonable for someone in an abusive relationship.

Discussion. This case illustrates how the “reasonableness” test applied against justification defenses may be made to conform to the particular limitations of a psychological condition suffered by defendant at the time of the criminal act.