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Name: People v. Brown
Case #: S113929
Opinion Date: 08/02/2004
Citation: 33 Cal.4th 892
Summary

The Supreme Court granted review in this case to determine whether expert testimony regarding battered women’s syndrome and the behavior of victims of domestic violence was within the scope of Evidence Code section 1107 when the evidence showed that appellant battered the victim on only one occasion. Two Court of Appeal decisions had addressed the issue with opposite results. The Supreme Court in this opinion held that the evidence was admissible under section 801 because it would assist the trier of fact in evaluating the credibility of the victim’s trial testimony and earlier statements, by providing information about the tendency of domestic violence victims to recant their statements. The Court did not reach the question of whether the expert testimony was admissible under section 1107. J. Brown dissented, holding that the evidence regarding battered women’s syndrome was not relevant to any disputed fact, and the admission of it prejudiced appellant.