State v. Obeta

796 N.W.2d 282 (2011)

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State v. Obeta

Minnesota Supreme Court
796 N.W.2d 282 (2011)

  • Written by Arlyn Katen, JD

Facts

Nathan Obeta (defendant) was convicted of first- and third-degree sexual assault. M. B. alleged that Obeta forced her to have sex with him in a car in a parking lot. Afterward, M. B. unsuccessfully tried to find a ride home, then sat in a Taco Bell for a few hours before flagging down a police officer and reporting the rape. Obeta claimed that he and M. B. had had consensual sex. The Minnesota Court of Appeals reversed Obeta’s conviction and remanded Obeta’s case for a new trial. Before Obeta’s second trial, the prosecution (plaintiff) sought to introduce expert testimony that sexual-assault victims typically lacked physical injuries, did not fight their attackers, and delayed reporting. At a pretrial hearing, the prosecution presented recent studies that demonstrated that the public still believed myths that sexual-assault victims commonly resist their attackers, sustain physical injuries, and immediately report the attack. The trial court barred the testimony, reasoning that the Minnesota Supreme Court had prohibited the admission of expert testimony about typical rape-victim behavior in State v. Saldana, 324 N.W.2d 227 (Minn. 1982). The prosecution appealed, and the Minnesota Supreme Court expedited the appeal.

Rule of Law

Issue

Holding and Reasoning (Dietzen, J.)

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