State v. Edmunds

308 Wis. 2d 374 (2008)

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State v. Edmunds

Wisconsin Court of Appeals
308 Wis. 2d 374 (2008)

  • Written by Haley Gintis, JD

Facts

In 1996, the State of Wisconsin (plaintiff) prosecuted Audrey Edmunds (defendant) for the homicide of seven-month-old Natalie. The state believed that Natalie had suffered shaken baby syndrome while at Edmunds’s home. At trial, witnesses testified that Natalie was acting normally when her mother left her in Edmunds’s care. Edmunds testified that Natalie began crying after she was dropped off and eventually became limp. Edmunds introduced one medical expert witness, who testified that Natalie had suffered violent shaking that occurred before Natalie was in Edmunds’s care. Edmunds’s witness believed that Natalie had a lucid interval and then suffered a seizure. The state introduced multiple expert witnesses who testified that Natalie had suffered violent shaking immediately before her death and disagreed that a lucid period could have occurred. Edmunds was found guilty of first-degree reckless homicide. Edmunds filed a postconviction motion for relief. The motion was denied. In 2006, Edmunds filed a motion for a new trial based on newly discovered evidence because the medical community’s understanding of shaken baby syndrome had changed since 1996. Edmunds introduced six medical expert witnesses, who testified that there was now a debate on the symptoms of shaken baby syndrome. The state introduced four expert witnesses, who testified that the understanding of shaken baby syndrome in 1996 was still valid. The circuit court concluded that Edmunds had newly discovered credible evidence but denied the motion on the ground that the state had provided more convincing credible evidence. Edmunds appealed.

Rule of Law

Issue

Holding and Reasoning (Dykman, J.)

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