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Com. v. Gibbons

Superior Court of Pennsylvania
Apr 7, 1989
556 A.2d 915 (Pa. Super. Ct. 1989)

Summary

In Commonwealth v. Gibbons, 383 Pa. Super. 297, 556 A.2d 915 (1989), the court held it was error to admit expert testimony regarding inconsistency even though the defendant based his case on inconsistency.

Summary of this case from Duckett v. State

Opinion

Argued November 29, 1988.

Filed April 7, 1989.

Appeal from the Court of Common Pleas, Cambria County, Criminal Division, Nos. 409A 409C of 1987, Long, J.

Ralph T. Forr, Jr., Altoona, for appellant.

Theresa Homady, Assistant District Attorney, Edensburg, for Com., appellee.

Before ROWLEY, DEL SOLE and MONTGOMERY, JJ.


At the conclusion of a jury trial, the appellant was found guilty of harassment and corruption of minors. After the trial court denied the appellant's timely filed post-verdict motions, he was sentenced to one to four years imprisonment and fined on the corruption of minors charge and forty-five to ninety days and fined on the harassment charge. This direct appeal was then timely commenced. For the reasons which follow, we are constrained to vacate the judgment of sentence and remand the matter for a new trial.

The appellant's sentence for harassment was concurrent to his sentence for corruption of minors.

The appellant raises eight issues for our review. Because of our disposition of the first issue presented, it is not necessary to reach the remaining issues. In his first issue, the appellant argues the trial court erred in permitting a psychologist, Dr. Maxine Kane, to testify concerning the behavior of incest victims in an attempt to bolster the credibility of the victim. In its brief to this Court, the Commonwealth acknowledges that "[h]er testimony concerned the general dynamics of child sexual abuse and the behavior patterns of its victims, particularly child incest victims." Indeed, in responding to the argument in the appellant's post-verdict motions, the trial court wrote:

Dr. Kane's testimony was relevant, material and probative. She testified as an expert in the general realm of incest, but that testimony specifically related to matters in issue during the trial. Dr. Kane elicited knowledge with regard to the fear, anxiety, and betrayal of trust which victims experience. She testified to the secrecy and non-disclosure surrounding such activity, the difficulty of remembering details from surrounding dates and times and the inconsistency attached thereto. Further, she testified as to the disassociation and disguised presentation that occurs as a result of such abuse. (T. 1/12/88 pp. 136-140)

. . . Dr. Kane's testimony was relevant and probative to matters in issue. Dr. Kane's testimony was relevant and probative in that the jury could infer that gaps and inconsistencies in the victim's testimony stemmed from the psychological dynamics of incest rather than from fabrication or fantasy.

Trial Court Opinion at 6. (Emphasis supplied)

We have reviewed the testimony of Dr. Kane and agree with the trial court's accurate observation as to its intended purpose. However, when the trial court's opinion was prepared, it did not have the benefit of this Court's recent decision in Commonwealth v. Emge, 381 Pa. Super. 139, 553 A.2d 74 (1988), where a panel of this Court ruled similar testimony inadmissible.

In Emge, the Commonwealth's psychologist, Dr. Anthony Mannarino, testified as to "[w]hether the changes in the child's behavior in this case were `consistent with, generally speaking, a victim of child sexual abuse. . . .'" Id., 381 Pa. Super. at 143, 553 A.2d at 76. The panel concluded that testimony "which matches up the behavior of known victims of child sexual abuse with that of an alleged victim can serve no purpose other than to bolster the credibility of the alleged victim, and this purpose is patently prohibited." Id., citing, Commonwealth v. Rounds, 518 Pa. 204, 207, n. 4, 542 A.2d 997, 999, n. 4 (1988); Commonwealth v. Davis, 518 Pa. 77, 541 A.2d 315 (1988); Commonwealth v. Seese, 512 Pa. 439, 517 A.2d 920 (1986).

The Commonwealth argues strenuously that Dr. Kane's testimony was necessary because "[t]he [appellant's] entire case rested on alleged inconsistencies with the victim's behavior and words, and without the expert testimony proferred by Dr. Kane, the jury would have had no idea whether these were truly inconsistencies indicating the victim was a liar or whether . . . the victim's actions and words were representative of a mechanism of coping. . . ." Appellee's Brief at 8. We note that in the instant case, as opposed to what occurred in Commonwealth v. Emge, the psychologist did not testify that the accusing child's behavior matched the behavior of known victims of child sexual abuse. Nevertheless, we can only conclude that the probative value of Dr. Kane's testimony is clearly outweighed by the prejudicial impact of admitting it. "A defendant would find little solace in the knowledge that [his] conviction resulted from the jury's belief that the accuser acted in a way that child sexual abuse victims are believed to act, as a class." Commonwealth v. Emge, 381 Pa. Super. at 143, 553 A.2d at 76. In this case, as in Commonwealth v. Emge, supra, the jury had the opportunity to see, hear, and evaluate the child accuser's testimony, as well as that of the other prosecution witnesses, in light of the appellant's own testimony and that of the defense witnesses. "Our faith lies in the jurors' ability to rely on the ordinary experience of life, their common knowledge of the natural tendencies of human nature — including those of a child — and their observations of the character and demeanor of the opposing witnesses." Commonwealth v. Emge, 381 Pa. Super. at 145, 553 A.2d at 77.

For the foregoing reasons, we are constrained to vacate the judgment of sentence and remand the matter for a new trial. Jurisdiction relinquished.


Summaries of

Com. v. Gibbons

Superior Court of Pennsylvania
Apr 7, 1989
556 A.2d 915 (Pa. Super. Ct. 1989)

In Commonwealth v. Gibbons, 383 Pa. Super. 297, 556 A.2d 915 (1989), the court held it was error to admit expert testimony regarding inconsistency even though the defendant based his case on inconsistency.

Summary of this case from Duckett v. State

In Commonwealth v. Gibbons, 383 Pa. Super. 297, 556 A.2d 915, alloc. denied, 523 Pa. 647, 567 A.2d 651 (1989), an expert testified concerning the behavior patterns of child sexual abuse victims and the general dynamics of child sexual abuse. The expert did not attempt to compare alleged victim's behavior to that of known victims of child sexual abuse.

Summary of this case from Com. v. Garcia

In Commonwealth v. Gibbons, 383 Pa. Super. 297, 556 A.2d 915 (1989), the testimony of the expert was similar to that offered in the instant case.

Summary of this case from Com. v. Purcell
Case details for

Com. v. Gibbons

Case Details

Full title:COMMONWEALTH of Pennsylvania, Appellee, v. Harry Robert GIBBONS, Appellant

Court:Superior Court of Pennsylvania

Date published: Apr 7, 1989

Citations

556 A.2d 915 (Pa. Super. Ct. 1989)
556 A.2d 915

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