Wednesday, January 14, 2009

Battered Spouse Syndrome Gets Another Look In Iowa

State v. Price, no. 07-1659 (Iowa Ct. App. Dec. 17, 2008)

Price stabbed her abusive significant other to death and was charged with voluntary manslaughter. Price pleaded not guilty and noticed the state on a defense of diminished responsibility, whereupon the state amended the trial information upward to second degree murder. Price hired an expert witness who would testify on her behalf about the battered spouse syndrome. 

The state argued that the testimony was irrelevant and the court agreed, finding that the stabbing arose out of a confrontation rather than being a non confrontational homicide. Price testified in her own defense that she feared for her life and had been advised by friends that the boyfriend would stop beating Price if she stabbed him.

After the first jury couldn't return a verdict Price again attempted to introduce battered spouse syndrome evidence with a different expert witness, and the testimony was again refused by the court for the same reasons, that the jury did not need an expert to tell them about the defendant's state of mind.

After the second trial Price was convicted of voluntary manslaughter and appealed. The court of appeals noted that battered spouse syndrome evidence was admissible under State v. Rodriquez, 636 N.W.2d 234 (Iowa 2001) and State v. Griffin, 564 N.W.2d 370 (Iowa 1997). 

The court then reviewed cases from other states where battered spouse syndrome evidence was relevant to a claim of self defense and found them informative and persuasive.

The court concluded that although battered spouse syndrome was not in itself a defense, it could aid the jury in determining whether the defendant's fear and self defense claims were reasonable.

What's the takehome?  First, Price's friends were correct in their assessment that stabbing her boyfriend would cure him of the abuse habit.  

More importantly, we're likely to see more battered spouse syndrome evidence presented in future cases. 

The brutality's unimaginable to those who haven't experienced it. 

It's serious stuff, folks. Educate yourselves.


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