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United States v. St. Pierre

812 F.2d 417 (1987)

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United States v. St. Pierre

United States Court of Appeals for the Eighth Circuit
812 F.2d 417 (1987)

  • Written by Arlyn Katen, JD

Facts

A federal jury convicted Ronald Kaye St. Pierre (defendant) of two counts of carnal abuse for sexually abusing his stepdaughter, T. In October 1985, T. and her mother left St. Pierre’s household to stay at a domestic-violence shelter. That month, T. told her mother that St. Pierre had sexually abused T. at least 50 times since July 1984. A medical examination corroborated T.’s disclosure. The federal district court denied St. Pierre’s pretrial motion for government funding to have an expert examine St. Pierre to determine whether he fit the profile of a sexual offender. At trial, the prosecution (plaintiff) presented Dr. Mary Curran, a clinical psychologist who examined T. as an expert witness. Curran testified that the scientific community recognized certain emotional and psychological characteristics as common to many sexually abused children. Curran listed the common characteristics and described which of those characteristics T. possessed. St. Pierre appealed from his conviction to the United States Court of Appeals for the Eighth Circuit, arguing in relevant part that the trial court had erred by (1) admitting expert testimony about common traits of sexually abused children and (2) denying St. Pierre’s potential expert testimony that St. Pierre did not fit the profile of a sexual offender.

Rule of Law

Issue

Holding and Reasoning (Woods, J.)

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