## Facts

- The defendant was charged with first-degree kidnapping, second-degree assault, third-degree criminal mischief, first-degree unlawful restraint, threatening, and breach of the peace.
- The victim, the defendant’s wife, went to police with three children and gave a detailed signed written statement describing severe domestic abuse, threats, restraint, and property destruction occurring the prior evening.
- At trial, the victim recanted and denied the abuse; she testified that she fabricated the police statement and claimed she had tied up and assaulted the defendant.
- The prosecution introduced the victim’s prior written statement as a prior inconsistent statement for impeachment and as substantive evidence.
- The prosecution also presented expert testimony from a sociologist regarding battered woman syndrome to explain why a domestic-violence victim might protect an abuser and later recant.
- A jury convicted the defendant on all counts, and the trial court imposed an effective twenty-year sentence, suspended after ten years, with probation.
- The defendant appealed, challenging admission of the prior statement and the expert testimony.

## Issues

1. Whether the trial court properly admitted the victim’s signed written police statement, inconsistent with her trial recantation, as substantive evidence under the prior-inconsistent-statement hearsay exception.
2. Whether the trial court properly admitted expert testimony on battered woman syndrome to explain the victim’s recantation without improperly bolstering credibility, requiring general-acceptance screening, or exceeding the expert’s qualifications.

## Decision

- The Supreme Court of Connecticut affirmed the convictions.
- The court held that the victim’s signed, detailed statement given soon after the events bore sufficient reliability to be used both for impeachment and substantively under the prior-inconsistent-statement exception.
- The court concluded the victim’s categorical trial denial was sufficiently inconsistent with her prior account to satisfy the foundation for substantive admission.
- The court upheld admission of battered woman syndrome expert testimony as helpful to the jury in understanding recantation and victim behavior.
- The court held general-acceptance review was not a prerequisite for this type of behavioral-explanation testimony.
- The court found the expert adequately qualified and determined the testimony did not invade the jury’s credibility function because it did not directly opine that the victim was truthful.

## Legal Principles

- A witness’s signed prior inconsistent statement may be admitted as substantive evidence when reliability safeguards are present, including the witness’s availability for cross-examination and circumstances indicating trustworthiness.
- A categorical recantation at trial can supply the inconsistency needed to admit a prior detailed account as substantively probative.
- Expert testimony is admissible when specialized knowledge beyond ordinary juror experience assists the factfinder in evaluating evidence, including explaining behavior that may appear counterintuitive.
- Expert testimony explaining battered woman syndrome may be admitted to aid understanding of recantation and related conduct, so long as it is general and does not directly vouch for a witness’s truthfulness.
- General-acceptance screening is not automatically required for social-science-based expert testimony offered to interpret behavior rather than to establish novel scientific proof.

## Conclusion

The court affirmed the defendant’s convictions, holding that the recanting victim’s signed prior statement was properly admitted as substantive evidence and that expert testimony on battered woman syndrome was properly admitted to help the jury assess recantation without deciding credibility for them.


State v. Borrelli, 629 A.2d 1105 (Conn. 1993)