Skinner v. State

Brad Skinner (defendant) was arrested and charged with committing aggravated assault and battery on his wife for a fight in which she alleged that he held a knife to her throat and threatened to kill her. A 911 operator overheard Skinner’s threat. During Skinner’s trial, Skinner’s wife testified about the subject assault, another assault after Skinner’s arrest, and Skinner’s threat that she better not testify regarding his use of a knife. The police found a knife in Skinner’s pocket when he was arrested. The state presented the testimony of an expert on battered-woman syndrome during its case-in-chief to aid the jury. During the expert’s testimony, he testified about domestic violence and indicated that a batterer’s rage and violence sometimes escalated. Skinner had not offered character evidence. The expert did not testify regarding Skinner’s particular character traits; however, the expert did address the cycle of violence, abbreviated remorse, escalation in violent conduct, and controlling patterns of batterers. Skinner was convicted and sentenced to life in prison under Wyoming’s habitual-crimes law, given that this was his ninth felony conviction. Skinner appealed his conviction, arguing in part that the portion of the expert’s testimony in which he discussed the profile of a batterer was inadmissible. Skinner argued that the expert’s testimony left the jury with the implication that he behaved in conformity with the batterer’s profile and, in fact, threatened his wife with a knife. Skinner argued that the only reason for testimony regarding a batterer’s behavior was to suggest to the jury that because Skinner had battered his wife before, he had committed the aggravated assault at issue while brandishing a knife.