Oregon v. Sanchez-Alfonso
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The issue before the Supreme Court in this case was whether a physician's conclusion that defendant physically abused a child met the requirements for admissibility of scientific evidence. The child in this case, C, was approximately 18 months old when he arrived at the emergency room with multiple injuries, including a golf-ball-sized lump on his forehead and a fractured skull. The state accused defendant of causing C's injuries and charged him with two counts of criminal mistreatment and first- and third-degree assault. To prove first-degree assault, the state had to show that defendant had caused C "serious physical injury," defined as injury that "creates a substantial risk of death." The jury convicted defendant of third-degree assault and two counts of criminal mistreatment. The jury acquitted defendant on the charge of first-degree assault, but found him guilty of the lesser-included offense of second-degree assault. Like first-degree assault, second degree assault requires a finding that the inflicted injury created a substantial risk of death. Upon review of the trial court record, the Supreme Court concluded that the expert's diagnosis was not limited to determining the cause of C's injuries, but included a conclusion that C's injuries were the result of child abuse. That aspect of the expert's diagnosis addressed a second disputed issue, whether defendant's actions were intentional or accidental. Because the Court could not conclude that there was little likelihood that the admission of the expert's diagnosis did not affect all of defendant's convictions, the Court also could not conclude that the trial court's error was harmless as to the convictions for first degree mistreatment and third-degree assault. The decision of the Court of Appeals was therefore reversed, and the case remanded to the trial court for further proceedings.
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