## Facts

- Nathan Obeta was convicted by a jury of first- and third-degree criminal sexual conduct under Minnesota law.
- The court of appeals reversed the convictions due to the cumulative effect of trial errors and remanded for a new trial.
- Before retrial, the State sought a pretrial ruling allowing expert testimony that sexual-assault victims often (1) delay reporting, (2) show no visible physical injuries, and (3) may act submissively, to rebut an anticipated consent defense.
- The district court denied the request, concluding that prior precedent barred such expert testimony.
- The State took an interlocutory appeal; the Minnesota Supreme Court granted accelerated review to resolve the evidentiary question.
- The case involved evidence the complainant reported the assault hours later and that a SANE examination showed no vaginal trauma, while the defense theory was that the sexual intercourse was consensual.

## Issues

1. Whether prior Minnesota precedent categorically prohibits expert testimony about typical sexual-assault victim behaviors when offered to rebut a consent defense.
2. If not categorically barred, under what conditions a district court may admit expert opinion evidence on delayed reporting, lack of physical injury, and submissive conduct.

## Decision

- The Minnesota Supreme Court exercised inherent supervisory power to decide the evidentiary issue due to its statewide importance.
- The court held that the relevant precedent had been interpreted too broadly and does not impose a blanket exclusion of general expert testimony on typical sexual-assault victim behavior.
- The court held that, in consent-defense criminal sexual conduct cases, a district court has discretion to admit expert testimony on the typicality of delayed reporting, lack of physical injuries, and submissive conduct if the testimony is helpful to the jury and has foundational reliability.
- The court reversed the district court’s exclusionary order and remanded for further proceedings.

## Legal Principles

- Expert opinion evidence on typical sexual-assault victim behaviors is not categorically inadmissible; admissibility depends on ordinary expert-evidence requirements and trial-court discretion.
- Such expert testimony may be admitted to assist jurors in evaluating evidence that might be misunderstood due to common misconceptions (e.g., expectations of immediate reporting, physical resistance, or injury).
- Expert testimony is impermissible if it effectively vouches for the complainant’s credibility or opines that the complainant was in fact raped; permissible testimony must remain general and non-vouching.
- Admission requires (1) helpfulness to the jury and (2) foundational reliability of the expert opinion.

## Conclusion

The court rejected a categorical reading of prior precedent and held that, when consent is disputed, trial courts may admit carefully limited and reliable expert testimony describing typical sexual-assault victim behaviors—such as delayed reporting, absence of physical injury, and submissive conduct—so long as it assists the jury without vouching for the complainant.


State v. Obeta, 796 N.W.2d 282 (Minn. 2011)