New Mexico v. Alberico

Ralph Alberico (defendant) was charged with sexually abusing a minor (the victim). At the trial, the state (plaintiff) offered expert testimony from Dr. Barbara Lenssen, a clinical psychologist. Lenssen testified that the victim suffered from post-traumatic stress disorder (PTSD) consistent with sexual abuse. PTSD was a diagnosis for a psychological condition that resulted from a traumatic incident, such as sexual abuse. The theory behind PTSD was that a traumatic incident like sexual abuse caused certain identifiable symptoms in a victim. Hence, in evaluating the victim for PTSD, Lenssen compared the victim’s symptoms with the known symptoms of sexual abuse. Lenssen concluded that the victim suffered from PTSD because the victim’s symptoms were consistent with the known symptoms of sexual abuse. Additionally, Lenssen testified that the American Psychiatric Association (APA) published a list of diagnostic criteria for PTSD in the Diagnostic and Statistical Manual of Mental Disorders (DSM III-R). This meant that PTSD was subject to scientific scrutiny and empirical verification. The trial court admitted evidence of the PTSD diagnosis. Subsequently, Alberico was convicted. The court of appeals overturned Alberico’s conviction, finding that the trial court erred in admitting evidence of the PTSD diagnosis. The state appealed to the New Mexico Supreme Court.