People v. Williams, 20 N.Y.3d 581 (2013)
Expert testimony on Child Sexual Abuse Accommodation Syndrome (CSAAS) is admissible to explain a victim’s behavior that might seem unusual, but hypothetical questions must not be tailored to mirror the specific facts of the case to avoid bolstering the victim’s credibility.
Summary
The New York Court of Appeals addressed the admissibility of expert testimony on Child Sexual Abuse Accommodation Syndrome (CSAAS) in a case involving multiple sex crime charges. The Court held that while general expert testimony on CSAAS is permissible to explain a victim’s behavior, hypothetical questions mirroring the specific facts of the case improperly bolster the victim’s credibility. However, the Court found the error harmless due to overwhelming evidence of the defendant’s guilt. The case clarifies the boundaries of expert testimony in child sexual abuse cases, emphasizing the need to avoid implying an expert’s opinion on the victim’s credibility.
Facts
Defendant was charged with sex crimes against two 12-year-old girls: AW, the daughter of his girlfriend, and PW, the girlfriend’s younger sister who frequently visited. PW reported the abuse to a school official in May 2007. At trial, both AW and PW testified in detail about the alleged sexual acts. A physician testified that the findings from PW’s examination were consistent with her allegations.
Procedural History
Defendant was convicted on all counts after a bench trial. The Appellate Division modified the judgment on other grounds, but otherwise affirmed the conviction, finding the expert testimony admissible. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether the trial court erred in admitting expert testimony on CSAAS that included hypothetical questions mirroring the specific facts of the case?
2. Whether the defendant was denied effective assistance of counsel?
Holding
1. Yes, because the prosecutor tailored the hypothetical questions to include facts concerning the abuse that occurred in this particular case. Such testimony went beyond explaining victim behavior that might be beyond the ken of a jury, and had the prejudicial effect of implying that the expert found the testimony of this particular complainant to be credible.
2. No, because defendant’s claim that he was denied the effective assistance of counsel is without merit.
Court’s Reasoning
The Court of Appeals acknowledged that expert testimony on CSAAS can be admissible to explain behaviors of a victim that might appear unusual or that jurors may not be expected to understand, particularly why a child may delay reporting sexual abuse. The Court cited People v. Spicola, where it upheld the admission of CSAAS expert testimony to rehabilitate a complainant’s credibility, so long as the expert did not offer an opinion as to whether the victim was actually abused.
However, the Court found that the expert’s testimony in this case exceeded permissible bounds when the prosecutor asked hypothetical questions mirroring the specific facts of the alleged abuse. The court stated that such testimony “went beyond explaining victim behavior that might be beyond the ken of a jury, and had the prejudicial effect of implying that the expert found the testimony of this particular complainant to be credible—even though the witness began his testimony claiming no knowledge of the case before the court.”
Despite finding this error, the Court deemed it harmless, stating that “the evidence of defendant’s guilt was overwhelming and there was no significant probability that, but for the introduction of the erroneous portion of his testimony, defendant would have been acquitted.” Both victims testified in detail, and PW’s testimony was corroborated by medical evidence.
The Court did not find merit in the defendant’s claim that he was denied effective assistance of counsel and affirmed the Appellate Division’s order.