## Facts

- Leonard Allen Grecinger, Sr. was convicted of attempted second-degree murder and third-degree assault for a severe beating of Barbara Skoglund, his on-and-off partner.
- Skoglund described a multi-year relationship involving repeated abuse and stated she feared retaliation if she pursued legal protection.
- At a motorcycle-club after-party, Skoglund testified she confronted Grecinger about being with another woman and went into a bathroom.
- Skoglund testified Grecinger followed her into the bathroom, beat and choked her into unconsciousness, and threatened to kill her if she left him.
- After the incident, Skoglund initially identified Grecinger to police, later recanted and attributed the assault to unknown assailants, then years later renewed accusations and pursued charges.
- At trial, the defense attacked Skoglund’s credibility in opening statement and through cross-examination, focusing on inconsistent statements and delayed reporting.
- In its case-in-chief, the State presented expert testimony describing battered woman syndrome and typical behaviors of victims; the expert did not testify that Skoglund had the syndrome or that she was truthful.

## Issues

1. Whether expert testimony describing battered woman syndrome is admissible in the prosecution’s case-in-chief after the defense attacks the complainant’s credibility, under Minn. R. Evid. 608(a).
2. Whether such expert testimony is admissible under Minn. R. Evid. 702 to help the jury understand conduct such as recantation, continued association with the alleged abuser, and delayed reporting.
3. Whether limiting the expert to general syndrome characteristics (without diagnosing the complainant or opining on truthfulness) avoids improper vouching and undue prejudice.

## Decision

- The Minnesota Supreme Court affirmed the conviction.
- The court held the battered woman syndrome testimony was properly admitted in the State’s case-in-chief after the defense attacked Skoglund’s credibility in opening statement and cross-examination.
- The court held the testimony satisfied Rule 702 because it assisted the jury in evaluating behavior commonly seen in abuse victims that might otherwise be viewed as inconsistent with truthful reporting.
- The court approved the trial court’s limits on the testimony: the expert could describe the syndrome and its characteristics, but could not state that Skoglund had the syndrome or that her allegations were true.

## Legal Principles

- Under Minn. R. Evid. 608(a), rehabilitative evidence bearing on a witness’s credibility may be admitted after the witness’s character for truthfulness has been attacked.
- Expert testimony is admissible under Minn. R. Evid. 702 when it helps the jury understand evidence or assess facts in issue, including seemingly counterintuitive victim conduct in domestic abuse contexts.
- In a prosecution of an alleged batterer, battered woman syndrome evidence may be admitted in the State’s case-in-chief if (a) credibility has been attacked and (b) the testimony is limited to general syndrome characteristics.
- Expert testimony may not diagnose the complainant with battered woman syndrome or directly opine on the complainant’s truthfulness, to avoid vouching and to preserve the jury’s role.
- Trial courts retain discretion to exclude or limit expert testimony that is not helpful or that carries unfair prejudice.

## Conclusion

The court upheld admitting general battered woman syndrome testimony in the prosecution’s case-in-chief once the defense attacked the complainant’s credibility, reasoning that limited explanatory testimony can assist jurors in evaluating recantation and delayed reporting without permitting expert diagnosis or credibility vouching.


State v. Grecinger, 569 N.W.2d 189 (Minn. 1997)