## Facts

- Barbara Bonner was married to Curtis Bonner, who repeatedly subjected her to physical and mental abuse, including assaults and at least one incident involving a firearm.
- Bonner had contacted police on multiple occasions and had sought divorce assistance but remained in the relationship.
- On the night of the killing, after Curtis had been drinking, he hit Bonner again.
- Bonner fought back, obtained a knife, and stabbed Curtis, causing his death.
- At trial, Bonner asserted self-defense and sought to present expert testimony on battered woman syndrome (BWS) to explain her perception of danger and the reasonableness of her actions.

## Issues

1. Whether expert testimony on battered woman syndrome is admissible to assist the jury in evaluating the reasonableness of a defendant’s belief in imminent danger for purposes of self-defense.
2. Whether the trial court abused its discretion by excluding Bonner’s proffered BWS expert testimony on prejudice/confusion grounds.
3. Whether exclusion of the BWS testimony was harmless error in a case where self-defense was a central theory.

## Decision

- Bonner was charged with and convicted of manslaughter under Ala. Code § 13A-6-3 and received a split 15-year sentence (two years custody, followed by probation).
- The Alabama Court of Criminal Appeals reversed the conviction and remanded.
- The court held that BWS expert testimony was relevant and admissible to aid the jury in deciding whether Bonner had reasonable grounds for an honest belief that she faced imminent danger.
- The court concluded the trial court’s exclusion of the BWS expert testimony was an abuse of discretion and not harmless.

## Legal Principles

- When self-defense is in issue, expert testimony on battered woman syndrome may be admitted to help the jury assess whether the defendant reasonably believed deadly force was necessary to prevent imminent harm.
- BWS testimony may be used to address common misconceptions about battered defendants and to explain behavior and perceptions that jurors might otherwise misunderstand.
- Excluding otherwise admissible BWS expert evidence based on generalized concerns about prejudice or juror confusion can be an abuse of discretion when the evidence bears directly on the reasonableness element of self-defense.
- Erroneous exclusion of BWS expert testimony is not harmless when it could materially affect the jury’s evaluation of the defendant’s claimed perception of imminent danger.

## Conclusion

The court reversed Bonner’s manslaughter conviction because the trial court improperly excluded battered woman syndrome expert testimony that was directly relevant to the jury’s assessment of the reasonableness component of self-defense, and the error could have affected the verdict.


Bonner v. State, 740 So. 2d 439 (Ala. Crim. App. 1998)