State v. Chauvin

846 So. 2d 697 (2003)

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State v. Chauvin

Louisiana Supreme Court
846 So. 2d 697 (2003)

  • Written by Haley Gintis, JD

Facts

In 1999, 15-year-old AC and 14-year-old AL were in AL’s living room when 34-year-old Amos Chauvin (defendant) went into the room and began molesting AC. Chauvin left the room but then returned to molest AC again. The same day, Chauvin also forcefully kissed AL. The next day, AL told AC’s sister what Chauvin had done. AC’s sister reported the incident to the police department. The State of Louisiana (plaintiff) charged Chauvin with multiple counts of indecent behavior with juveniles. At the trial, the state introduced licensed social worker Renee Thompson Ring. Ring testified that she had treated AC following the incident and diagnosed her with post-traumatic stress disorder (PTSD). Additionally, Ring testified that AC’s symptoms were consistent with symptoms that a victim of sexual abuse would show. The state used Ring’s testimony as substantive evidence that AC had been sexually abused. Chauvin objected. The objection was overruled. Chauvin was convicted of the charges. Chauvin appealed. The court of appeals reversed the conviction. The state petitioned the Louisiana Supreme Court to consider whether Ring’s testimony could be used as substantive evidence that AC had been sexually abused by Chauvin. The court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Knoll, J.)

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