State v. Reed

The proponent of scientific evidence must demonstrate that the proposed evidence is based on scientifically valid principles and that it is pertinent to the issue to which it is directed

Defendant appealed his conviction for first-degree rape and first-degree sexual abuse. He asserted that the trial court erred in admitting certain expert testimony. The victim was Defendant’s adult daughter, who suffers from severe intellectual disabilities. At trial, the state had presented expert testimony from a clinical psychologist (the witness), who testified that the victim was not competent to consent to sexual activity. Defendant objected to the witness’s conclusion, claiming that her testimony was lacking any foundation in scientific evidence. The trial court concluded that the testimony was admissible for its relevance and its scientific validity, and thus it denied Defendant’s motion to exclude. The Court found that the proponent of scientific evidence must demonstrate that the proposed evidence is based on scientifically valid principles and that it is pertinent to the issue to which it is directed. The Court enumerated the following factors, and held that the evaluation methods used by the witness, to reach her conclusion, were scientifically valid: the technique’s general acceptance in the field; the expert’s qualification and stature; the use which has been made of the technique; the potential rate of error; the existence of specialized literature; the novelty of the invention; and the extent to which the technique on the subjective interpretation of the expert. The Court found that the trial court did not err in denying Defendant’s motion to exclude the testimony of the witness. Affirmed.