## Facts

- Bryan Haines and Jacqueline Bohley were in a long-term, cohabiting relationship marked by conflict and controlling behavior by Haines.
- In October 2001, Bohley reported domestic violence; Haines was convicted, jailed briefly, and a protection order issued, but the couple later reconciled and resumed living together.
- On March 31, 2002, Bohley alleged Haines beat her, forced her into a crawlspace, and threatened to kill her; corroboration was limited, and the defense emphasized her post-incident behavior (sexual contact with Haines, false explanations for injuries, delayed reporting).
- In April 2002, Bohley alleged further abuse; coworkers and police responded after she sought help, and photographs and third-party testimony corroborated injuries.
- A jury convicted Haines of kidnapping, abduction, and domestic violence.
- Over objection, the trial court admitted expert testimony on battered-woman syndrome (BWS) in the State’s case-in-chief, including testimony that Bohley’s conduct was consistent with BWS patterns.

## Issues

1. Whether the prosecution may introduce BWS expert testimony in its case-in-chief in a domestic-violence prosecution when the defendant does not assert self-defense.
2. Whether an expert may apply BWS concepts to the complainant by testifying that her behavior is consistent with that of a battered woman, without impermissibly vouching for credibility or implying guilt.

## Decision

- The Supreme Court of Ohio affirmed the convictions.
- The court held BWS expert testimony may be admitted in the State’s case-in-chief to help the jury understand behavior that might appear inconsistent with abuse allegations (e.g., reconciliation, lying about injuries, delayed reporting).
- The court held an expert may testify that the complainant’s behavior is consistent with behaviors associated with BWS, provided the expert does not opine that the complainant is telling the truth, that she is in fact a battered woman, or that the defendant committed the charged acts.
- The court concluded the probative value of the testimony was not substantially outweighed by unfair prejudice under evidentiary balancing principles, given the limits on the expert’s opinions.

## Legal Principles

- Expert testimony is admissible when it assists the trier of fact in understanding evidence or determining a fact in issue, including by explaining counterintuitive victim behavior in domestic-violence cases.
- The prosecution may present BWS evidence to explain or rehabilitate the complainant’s conduct; admissibility does not depend on a self-defense claim by the defendant.
- An expert may relate general syndrome characteristics to the complainant’s observed behavior as “consistent with” the syndrome, but may not directly vouch for credibility, diagnose the complainant as a battered woman for purposes of proving abuse occurred, or express an opinion on the defendant’s guilt.
- Trial courts retain discretion to exclude otherwise relevant expert testimony if unfair prejudice substantially outweighs probative value, and must enforce the boundary between explanatory testimony and credibility or guilt opinions.

## Conclusion

The court upheld admission of BWS expert testimony offered by the State to explain a complainant’s seemingly inconsistent behavior in a domestic-violence prosecution, while limiting such testimony to behavioral explanation and barring direct opinions on credibility or guilt.


State v. Haines, 112 Ohio St. 3d 393, 860 N.E.2d 91 (Ohio 2006)