Colorado v. Coons
Annotate this CaseThe trial court in this case admitted the generalized expert testimony offered by the State on the dynamics of domestic violence, ruling that it would be helpful to the jury and impliedly finding that it passed muster under CRE 403. A jury then returned guilty verdicts against the defendant Dylan Coons, for sexual assault, extortion (involving an unlawful act), extortion (involving a third party), and assault in the third degree. But a division of the court of appeals reversed the judgment of conviction, concluding that some of the State's generalized expert testimony did not fit the case. More specifically, the division ruled that the trial court abused its discretion in admitting expert testimony about some aspects of the Power and Control Wheel (a tool adopted by social scientists to explain the common dynamics of domestic violence), including “certain of the examples of abusive acts that abusers may commit.” According to the division, since this testimony had no logical relation to the facts of the case, it should have been excluded and the trial court’s failure to do so was reversible error. The Colorado Supreme Court held that generalized expert testimony fits a case if it has a sufficient logical connection to the factual issues to be helpful to the jury while still clearing the ever-present CRE 403 admissibility bar. "In evaluating the fit of generalized expert testimony, a trial court must be mindful of the purposes for which such testimony is offered—that is, the reasons why the proponent of the evidence has asked the expert to educate the jury about certain concepts or principles." Because the court of appeals employed a fit standard "inflexible and overly exacting," and because the trial court's decision to admit the challenged evidence was entitled to deference, the division erred. Judgment was reversed and the matter remanded for further proceedings.
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