State v. Stewart
West Virginia Supreme Court
719 S.E.2d 876 (2011)
- Written by Arlyn Katen, JD
Facts
A West Virginia jury convicted Rhonda Kay Stewart (defendant) of the first-degree murder of her husband. The trial court refused to allow Stewart to present eyewitness evidence that her husband had physically abused her throughout their 38-year marriage. The trial court also excluded expert testimony from Dr. David Clayman, a clinical and forensic scientist. Clayman would have testified that if the information provided to Clayman was credible, then Stewart met the criteria for battered-spouse syndrome (BSS) (also known as battered-woman syndrome, or BWS), a clinical concept that explains the psychological mindset and behavior of a person who has experienced repeated physical or mental abuse by a domestic partner. Clayman’s proffered testimony included an opinion about how Stewart’s history of spousal abuse may have impacted her mental condition when she shot her husband. The trial court reasoned that domestic-violence history was not relevant because Stewart did not claim self-defense and the evidence of abuse was too remote. The trial court also found that Clayman could not testify as an expert about BSS or Stewart’s experiences of abuse because Clayman had not diagnosed Stewart as fitting the profile of BSS to a reasonable degree of medical certainty. Stewart appealed to the West Virginia Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Ketchum, J.)
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