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People v. Aphaylath
Court of Appeals of New York
502 N.E.2d 998 (1986)
May Aphaylath (defendant), a Laotian refugee living in the United States for approximately two years, was indicted for the intentional murder of his wife of one month. At trial, Aphaylath sought to establish the affirmative defense of extreme emotional disturbance, based on the accumulation of stress relating to his refugee status and his jealously over his wife’s continued fondness for her ex-boyfriend. Aphaylath argued that both events caused him significant mental trauma that affected him for a substantial period of time, culminating in a total loss of self-control at the time of the killing. Additionally, Aphaylath sought to argue that, under Laotian culture, his wife’s conduct of displaying affection for another man brought sufficient shame upon Aphaylath and his family to trigger a loss of self-control. Aphaylath proffered testimony from two expert witnesses concerning the negative psychological effects encountered by Laotian refugees attempting to assimilate into American culture. The trial court excluded the expert testimony, because neither expert could testify specifically with respect to Aphaylath. Aphaylath was convicted, and he appealed.
Rule of Law
Holding and Reasoning
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