Michele K. Dague v. State of Alaska

Summary

The Alaska Supreme Court held that the trial court improperly excluded proposed testimony from the State's expert regarding the dynamics of child abuse, the mental state of child abusers, and the defendant's possible lack of awareness during the incident. The court concluded that the exclusion was not harmless because the testimony could have bolstered the defense expert's testimony on the central issue of whether Dague acted knowingly, and it reversed and remanded for a new trial.

Holdings

1. The exclusion of Dr. Krugman's testimony was not harmless because the testimony could have appreciably affected the jury's determination of whether Dague acted knowingly, an element of the second-degree murder charge.
2. Regardless of whether the exclusion constituted constitutional or nonconstitutional error, the error was prejudicial because it was not harmless even under the less demanding nonconstitutional harmless-error standard.

Questions Presented

1. Whether the trial court's exclusion of Dr. Krugman's proposed expert testimony concerning the dynamics of child abuse and the mental state of abusers was harmless error.
2. Whether the excluded testimony could have materially bolstered the defense expert's testimony and supported Dague's claim that she did not act knowingly.

Disposition

reversed_and_remanded