United States v. Nwoye, No. 14-3060 (D.C. Cir. 2016)Annotate this Case
Defendant was convicted of conspiring with her boyfriend to extort money from a prominent doctor with whom defendant had previously had an affair. The district court denied defendant's ineffective-assistance-of-counsel claim, holding that defendant was not prejudiced by trial counsel’s failure to introduce expert testimony on battered woman syndrome. The district court therefore did not need to (and did not) decide whether counsel’s performance was constitutionally deficient. The court concluded, however, that defendant was prejudiced by trial counsel’s failure to introduce expert testimony on battered woman syndrome. In this case, the duress instruction would have given jurors a legal basis upon which to vote not guilty, and the expert testimony on battered woman syndrome would have supported both elements of defendant’s duress defense. The factors here add up to a reasonable probability that the jury would have had a reasonable doubt respecting guilt if expert testimony on battered woman syndrome had been presented at defendant’s trial. Accordingly, the court reversed and remanded for the district court to decide whether counsel was constitutionally deficient in failing to present such testimony.