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Keywords

defendanttrialtestimonycircumstantial evidence

defendantappealverdicttestimonybeyond a reasonable doubt

Related Cases

State v. Dumlao, 3 Conn.App. 607, 491 A.2d 404

Facts

On March 7, 1983, the Dumlaos' two-year-old daughter was hospitalized with severe injuries, including a fractured spleen and multiple bruises, which were diagnosed as battered child syndrome. The child had been in pain, unresponsive, and severely dehydrated. The medical history provided by Paulino was inconsistent with the child's injuries, leading to suspicions of abuse. The defendants were charged with assault and risk of injury to a child, and while they were acquitted of assault, they were convicted of the latter charges.

The jury could reasonably have found the following facts: On March 7, 1983, the defendants' two year old daughter was hospitalized at Yale-New Haven Hospital after being transferred from the Naval Hospital in Groton where she was referred by a local pediatrician. The child, at the time the defendants took her to the pediatrician and she was hospitalized, was in pain, generally unresponsive to her environment, covered with abrasions and bruises, including an open lesion the size of a nickel under the left eye, severely dehydrated, and had internal abdominal injuries which were later diagnosed as a fractured spleen, pancreatitis and liver dysfunction.

Issue

Whether the trial court erred in admitting expert testimony on battered child syndrome and whether the evidence was sufficient to support the convictions of injury or risk of injury to a child.

The defendants appeal separately from their convictions, claiming in large part that the court erred in admitting certain evidence and that the evidence was insufficient for conviction.

Rule

Expert testimony regarding battered child syndrome is admissible if it aids the jury in determining the ultimate issue of guilt or innocence, and circumstantial evidence can be sufficient to support a conviction.

Expert testimony is permitted, in the court's discretion, “ ‘if the witness has a special skill or knowledge, beyond the ken of the average juror, that, as properly applied, would be helpful to the determination of an ultimate issue.’ ”

Analysis

The court found that the expert testimony on battered child syndrome was relevant and not inflammatory, as it provided necessary context for understanding the child's injuries. The jury was able to draw reasonable inferences from the circumstantial evidence presented, including the inconsistencies in the defendants' accounts and the severity of the child's injuries, which supported the conclusion that the defendants were guilty of the charges.

The court carefully excluded the use of inflammatory terms such as “child abuse” or “abused child,” and properly permitted the presentation of battered child syndrome solely as a medical diagnosis. Such testimony, like other medical testimony, is of obvious aid to the jury in its determination of the ultimate issue of guilt or innocence of the defendant.

Conclusion

The Appellate Court affirmed the convictions of Paulino and Aurora Dumlao, concluding that there was no error in the trial court's admission of evidence or in the jury's findings.

We therefore turn to the challenge to the sufficiency of the evidence. When a jury verdict is challenged on the ground that the evidence is insufficient to sustain the verdict, this court reviews whether “[t]he jury could have reasonably concluded, upon the facts established and the inferences reasonably drawn therefrom, that the cumulative effect of the evidence established the defendant's guilt beyond a reasonable doubt.”

Who won?

The State prevailed in the case, as the court upheld the convictions of the Dumlaos based on sufficient evidence of their guilt.

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