Byrd v. Brown

On July 26, 2002, Jimmy Byrd (defendant) violently assaulted his domestic partner, Jill Johnson, for failing to clean a dirty jar. Byrd refused to allow Johnson to obtain medical help. By July 31, Johnson’s pain became unbearable. Johnson took a taxi to the hospital without Byrd’s knowledge. A hospital examination revealed that Johnson needed emergency surgery due to the severe injuries she sustained from the assault. Johnson received the surgery and stayed in the hospital to recuperate. Byrd frequently visited Johnson. After an investigation into domestic abuse, the state of New York (defendant) pursued charges against Byrd. While at the hospital, Johnson cooperated with the state and provided testimony from the hospital for a grand jury proceeding. After Johnson was released from the hospital, she stopped cooperating. The state became concerned that Johnson might refuse to testify at Byrd’s trial. The state requested a hearing so that the court could determine whether Byrd had engaged in wrongful conduct to persuade Johnson against testifying. The court held the hearing. The state introduced evidence that while Byrd was detained awaiting trial, he had called Johnson about 450 times in violation of a protective order forbidding the contact. The state also introduced expert testimony on battered-woman’s syndrome. The expert testified that a victim suffering from battered-woman’s syndrome may be reluctant to testify against her perpetrator due to the coercive nature of the relationship. The trial court deferred judgment on the matter to see whether Johnson would testify at trial. Johnson appeared at Byrd’s trial but refused to answer any questions. The trial court then determined that Byrd had wrongfully caused Johnson’s refusal to testify by his repeated calls and history of abusive behavior. The trial court then allowed the expert to testify on battered-woman’s syndrome at trial. The trial court instructed the jury that the testimony was to be used for the sole purpose of explaining why a victim might not cooperate in her abuser’s trial. Byrd was found guilty of multiple counts of assault. Byrd appealed. The appellate division affirmed the trial court. Byrd filed an application for leave to appeal with the New York Court of Appeals. The New York Court of Appeals denied the request. Byrd filed a writ of habeas corpus in federal district court on the ground that the expert testimony violated his due-process rights to a fair trial.