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Name: People v. Wells
Case #: A099569
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 04/29/2004
Subsequent History: Rehrg. den. 5/26/04; Rev. den. 8/11/04

The trial court did not err in excluding expert testimony regarding the usual reactions of sexually abused children. On appeal from his conviction of several sex offenses against two minors, the defendant claimed that the trial court improperly excluded testimony by a defense expert regarding the normal reactions of trauma victims. The testimony had been offered to show that the demeanor of one of the minors was inconsistent with having been molested, and followed the testimony of a prosecution expert who described the various stages of child abuse accommodation syndrome. In regard to the prosecution expert’s testimony, the jury had been instructed that they could not consider the evidence as proof that a molestation had occurred. The Court of Appeal agreed with the trial court that admission of expert testimony concluding, based on a complaining witness’s demeanor, that the witness has not been molested would violate the spirit of the Supreme Court’s holding in People v. Bledsoe (1984) 36 Cal.3d 236. One justice was of the opinion that the evidence was improperly excluded, but found the error harmless.