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People v. Taylor

New York Court of Appeals
75 N.Y.2d 277 (1990)


Facts

A 19-year-old woman reported that she had been raped and sodomized at gunpoint. She arrived at home at approximately 11:00 p.m., woke her mother, and told her about the attack. The mother called the police, who came to their home. The victim told the police twice that she did not know who the attacker was. Shortly after that, at approximately 1:15 a.m., the victim was alone with her mother and stated that the attacker was John Taylor (defendant). The victim said she had known Taylor for years and had seen him the night before the attack as well. The victim repeated this to the police and identified Taylor from two separate lineups. The State of New York (plaintiff) charged Taylor with rape, sodomy, and sexual abuse. During the trial, the prosecution presented expert testimony that the victim suffered from rape trauma syndrome. According to the expert testimony, people who experience rape trauma syndrome may delay reporting a rape, may be unwilling to name an attacker that the person knows for a period of time following the attack, and may go through distinct stages after the attack, including appearing calm for a period of time. The prosecution offered the expert testimony to explain the victim’s initial statements that she did not know the attacker and to explain her calm demeanor. The trial court permitted this evidence to be presented to the jury, and the jury convicted Taylor of sodomy and attempted rape. In a separate case, an 11-year-old girl reported that she had been sexually assaulted by a stranger. The State of New York charged Ronnie Banks (defendant) with rape, sodomy, sexual abuse, and related crimes based on the age of the victim. The prosecution presented expert testimony that the victim suffered from rape trauma syndrome. This testimony was offered to prove that a rape occurred because the victim’s behavior following the attack was consistent with a person experiencing rape trauma syndrome. The trial court permitted this evidence to be presented to the jury, and the jury convicted Banks of the crimes related to the victim’s status as a minor. Taylor and Banks appealed, and the New York Appellate Division affirmed. Taylor and Banks appealed to the New York Court of Appeals. The appeals have been consolidated for review.

Rule of Law

Issue

Holding and Reasoning (Wachtler, C.J.)

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