Steward v. State

SULLIVAN, Justice,

dissenting.

Cases of alleged child abuse provide a particular challenge for the criminal justice system.

If trials are genuine searches for truth, that truth must be sought in light of society's modern understanding of children.... Adults who assume that their own perceptions, motivations, and fears are universal cannot empathize with children caught between the horrors of sexual abuse and the criminal justice system. Adults who doubt children because of false assumptions about their perception, memory, suggestibility, and truthfulness cannot fairly evaluate their testimony in the courtroom.

Billie W. Dziech and Charles B. Schudson, On Trial: America's Courts and Their Treatment of Sexually Abused Children 53 (1991). Expert testimony has proved to be helpful in meeting this challenge.

Recognizing that most jurors will not have experience that allows for a fully informed evaluation of a child's behavior and credibility, courts have thus permitted experts to help juries by testifying in three areas: (1) factors affecting credibility of children, (2) factors affecting behavior of child sexual abuse victims, (8) interpretations of special forms of child communication.

Id. at 157.

I believe our rules of evidence provide a fair yet flexible regime for determining whether any particular expert testimony proffered on the subject of sexual abuse is admissible. Assuming that the proffered testimony is relevant1 and will assist the jury in understanding the evidence or a fact at issue,2 and that the witness is properly qualified as an expert3 (issues not implicated by this case or by the majority opinion), the trial court must determine whether the scientific principles upon which the expert testimony rests are reliable4 As to the reliability of expert testimony concerning child sexual abuse accommodation syndrome and similar evidence, the majority sets general rules for the following three situations:

(1) Child sexual abuse accommodation syndrome evidence is presently5 not scientifically reliable enough to permit an expert to offer "an unreserved conclusion that the child in question has been abused."

(2) Child sexual abuse accommodation syndrome is also presently not scientifically reliable enough to permit the use of expert testimony "merely ... to imply the occurrence of abuse."

(8) However, child sexual abuse accommodation syndrome is presently scientifically reliable enough to permit the use of expert testimony to assist the factfinder in understanding a child's response to abuse when, but only when, the defense asserts or implies that the alleged child victim's conduct was inconsistent with the claim of abuse, or if the child recanted a prior allegation of abuse.

As to situation (1), I certainly agree that an expert may not comment directly on whether the child has been sexually abused or whether the child has testified truthfully. Ind.Evidence Rule 704. But as to situation (2), the Court of Appeals correctly pointed out that our rule has been that expert testimony that a putative rape victim's behavior was consistent with that of one who had in fact been raped merely tended to show that the victim had been raped and was not a direct opinion that the victim was telling the *501truth. Steward v. State (1994), Ind.App., 636 N.E.2d 143, 146-47 (citing Henson v. State (1989), Ind., 535 N.E.2d 1189, 1192-93). I see no basis for having different rules for child sexual abuse and for rape. And I also think that banning expert testimony because the "danger of the jury misapplying [the evidence] remains the same whether an expert expresses an explicit opinion ... or merely allows the jury to draw the final conclusion" has very restrictive implications for expert testimony generally.

I acknowledge the majority's citation of Daubert's observation that scientific evidence can be reliable for one purpose but not another, Daubert v. Merrell Dow Pharmaceuticals, Inc., - U.S. -, -, 113 S.Ct. 2786, 2796, 125 L.Ed.2d 469 (1993). It seems clear to me, however, that the purposes of the testimony in situations (2) and (3) are the same-to aid the jury in assessing the credibility of the child witness. While the former may be more prejudicial than the latter, that does not make the scientific principles upon which the former is based less reliable than the latter's.

I do not think we can say that the scientific principles upon which child sexual abuse accommodation syndrome is based are not reliable as direct evidence but are reliable as rebuttal evidence. In logic, either those principles are reliable for purposes of aiding the jury in assessing the child victim's eredi-bility or they are not. The majority cites dozens of opinions where such evidence was found to be reliable, at least for rebuttal purposes, and I would hold that to the extent that that authority establishes its reliability for rebuttal evidence, it establishes it for direct evidence as well.

Onee the trial court determines that expert testimony is admissible under Evidence Rule 702(b), the proffered testimony is still subject to challenge under Indiana Evidence Rule 403 which, as the majority points out, provides:

Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, misleading the jury, or by consideration of undue delay or needless presentation of cumulative evidence.

It is here, rather than under the rubric of scientific or expert testimony, that I think the real battle over the admissibility of child sexual abuse accommodation syndrome should be fought in most cases. We recently observed that scientific evidence is subject to particular scrutiny under Evidence Rule 403. Harrison v. State (1995), Ind., 644 N.E.2d 1243, 1252 (quoting Daubert, - U.S. at --, 113 S.Ct. at 2798, and Cornett v. State (1983), Ind., 450 N.E.2d 498, 503). But whether any particular evidence violates Evidence Rule 408 is a matter first and foremost for the trial court to decide: we review only for an abuse of discretion. Evans v. State (1994), Ind., 643 N.E.2d 877, 880. While Daubert's progeny suggest some heightened serutiny of such determinations is appropriate when scientific evidence is involved, In re: Paoli Railroad Yard PCB Litigation, 35 F.3d 717, 749-750 (3d Cir.1994), cert. denied sub nom. General Elec. Co. v. Ingram, - U.S. -, 115 S.Ct. 1253 (1995), I agree with the analysis given this evidence in this case by Judge Najam and concur in his view that it was not erroneous for the trial court to admit Dr. Watson's testimony6 More generally, I would hold that, while Evidence rule 704 prohibits the use of child sexual abuse accommodation syndrome evidence in situation (1), the reliability test of Evidence Rule 702(b) applies in the same way to such evi-denee in both situations (2) and (8), and that the admissibility of such evidence under Evidence Rule 403 is committed to the sound discretion of the trial court.

I would make one final observation. In Henson v. State, supra, this court reversed the conviction of an appellant convicted of rape on grounds that he was denied due process of law when the trial court refused to permit him to introduce evidence that the putative victim's conduct was not consistent with that which would have been predicted were she suffering from rape trauma syndrome. Henson, 504 N.E.2d at 1193-94. I cannot avoid the conclusion that today's opinion prohibits a defendant from offering child *502sexual abuse accommodation syndrome evidence in his own defense.

. Ind.Evidence Rule 401.

. Ind.Evidence Rule 702(a).

. Ind.Evidence Rule 702(a).

. Ind.Evidence Rule 702(b).

. While the majority says that such evidence is not "unreliable as a matter of law," the majority would permit trial courts to consider admitting the evidence only if future empirical research and scientific investigation resolves present doubts about reliability.

. The majority does not explicitly conclude that Dr. Watson's testimony was erroneously admitted but that is the only inference I can draw from its opinion.