## Facts

- The defendant was prosecuted in Georgia for the murder of his infant daughter.
- The State’s proof included medical and related evidence concerning injuries consistent with repeated abuse of the child.
- At trial, the prosecution presented expert testimony describing “battering parent” syndrome to explain patterns associated with caregivers who inflict recurring harm.
- The defendant challenged the admissibility and effect of the expert testimony and raised additional claims of trial error.
- The case reached the Supreme Court of Georgia on direct review of the conviction.

## Issues

1. Whether the trial court erred by admitting expert testimony concerning “battering parent” syndrome in a murder prosecution involving an infant victim.
2. Whether the expert evidence improperly invaded the jury’s role or was unfairly prejudicial relative to its probative value.
3. Whether asserted procedural or evidentiary errors warranted reversal of the conviction.

## Decision

- The Supreme Court of Georgia affirmed the conviction.
- The court held the expert testimony on “battering parent” syndrome was admissible to assist the jury in understanding evidence of repeated abuse and its relationship to the charged homicide.
- The court rejected the defendant’s arguments that admission of the expert testimony required reversal.
- The court found no reversible error in the remaining claims raised on appeal.

## Legal Principles

- Expert testimony is admissible when it assists the factfinder in understanding evidence or determining a fact in issue, including in cases involving patterns of abuse.
- Syndrome or pattern evidence may be admitted for explanatory purposes when tied to relevant facts and not offered as an improper direct opinion on guilt.
- Appellate courts will affirm a conviction where challenged evidentiary rulings fall within the trial court’s discretion and any claimed errors do not warrant reversal.

## Conclusion

The Supreme Court of Georgia affirmed the defendant’s murder conviction, holding that expert testimony concerning “battering parent” syndrome was properly admitted to aid the jury’s evaluation of evidence of repeated abuse and that the other asserted trial errors did not justify a new trial.


Sanders v. State, 303 S.E.2d 13 (Ga. 1983)