## Facts

- Dr. William Boyd Guthrie was convicted of murdering his wife, Sharon Guthrie, after she was found face down in an empty bathtub at their home.
- On May 14, 1999, Guthrie called 911 around 7:00 a.m., reporting Sharon was unconscious in the bathtub; she was hospitalized, never regained brain function, and died the next day.
- Autopsy toxicology showed sub-therapeutic amounts of several sedatives and a toxic, debilitating (but not independently fatal) level of temazepam.
- The pathologist estimated Sharon ingested about 20 temazepam capsules, concluded she drowned while incapacitated by the drug, and classified the death as not natural or accidental; the autopsy could not distinguish suicide from homicide.
- The prosecution theorized Guthrie drugged Sharon (including by adulterating chocolate milk), drowned her, and attempted to stage a suicide; evidence included Guthrie’s multiple temazepam prescriptions, computer activity suggesting a “suicide note” was created after Sharon’s death, and marital strain including Guthrie’s affair and Sharon’s divorce plans.
- To address the suicide-versus-homicide dispute, the State presented Dr. Alan Berman, a clinical psychologist specializing in suicidology, who described suicide risk factors and method patterns and opined Sharon did not die by suicide.
- Guthrie objected that Dr. Berman’s opinion improperly addressed the ultimate issue and invaded the jury’s role.

## Issues

1. Whether the trial court abused its discretion by admitting Dr. Berman’s suicidology testimony under South Dakota Rule of Evidence 702.
2. Whether an expert opinion that the decedent did not die by suicide is an impermissible “ultimate issue” opinion that effectively decides guilt.
3. If admitting the testimony was error, whether it required reversal of the murder conviction.

## Decision

- The South Dakota Supreme Court affirmed the conviction.
- The court held the trial court did not abuse its discretion in finding Dr. Berman qualified and his testimony reliable and helpful to the jury under Rule 702.
- The court held Dr. Berman’s opinion that Sharon did not die by suicide was not an impermissible opinion on Guthrie’s guilt and did not usurp the jury’s function.
- The court treated disputes about the expert’s assumptions and conclusions as issues for cross-examination and weight, not admissibility.

## Legal Principles

- Trial courts have broad discretion to admit expert testimony; appellate review is deferential as to both reliability and admissibility determinations.
- Expert testimony is admissible under Rule 702 when specialized knowledge will assist the trier of fact and the testimony is sufficiently reliable and relevant.
- Expert opinions may address ultimate issues of fact, but experts may not give direct legal conclusions that the defendant is guilty or that the defendant committed the charged offense.
- An expert may opine that circumstances are consistent or inconsistent with suicide, including a professional judgment that a death was not a suicide, when framed as an assessment of the manner of death rather than a guilt determination.
- Jury instructions that jurors are the sole factfinders and that expert opinions are not binding reduce the risk that expert testimony will substitute for the jury’s judgment.

## Conclusion

The court upheld admission of specialized suicidology evidence explaining suicide risk factors and method patterns and permitted an expert opinion that the death was not suicide, concluding it assisted the jury without constituting a direct opinion of the defendant’s guilt; the murder conviction was affirmed.


State v. Guthrie, 627 N.W.2d 401 (S.D. 2001)