## Facts

- Roy Young and Beatrice Patrick were involved in a long-term abusive relationship; Young did not dispute that he had repeatedly beaten Patrick over several years.
- Patrick testified before a federal grand jury about Young’s abuse and alleged kidnapping, but at trial she recanted and denied abuse and kidnapping.
- To explain Patrick’s recantation, the government offered Dr. Ann Wolbert Burgess, a psychiatric mental-health nurse with extensive professional experience and publications concerning crime victims and domestic violence.
- Dr. Burgess interviewed Patrick for over an hour and reviewed case materials including law-enforcement reports, Patrick’s grand-jury testimony, an order of protection, Young’s criminal history, correspondence, jail-call recordings, and defense interview notes; she later interviewed Young.
- Dr. Burgess testified that victims of ongoing domestic abuse commonly recant because they perceive limited means of escape, and that Patrick’s conduct was consistent with that pattern.
- The jury convicted Young of two federal domestic-violence-related offenses involving Patrick and acquitted him of kidnapping.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Evidence 702 and Daubert by admitting expert testimony describing common behavioral patterns of domestic-violence victims, including recantation.
2. Whether alleged methodological weaknesses—such as reaching a preliminary opinion before interviewing the defendant and not interviewing the victim’s friends or family—required exclusion rather than cross-examination.

## Decision

- The Seventh Circuit affirmed the judgment.
- The court held the district court did not abuse its discretion in admitting Dr. Burgess’s testimony under Rule 702 and Daubert.
- The court treated Young’s methodological objections as going to the weight of the testimony, not its admissibility.

## Legal Principles

- Under Rule 702 and Daubert, reliability is assessed flexibly, and the admissibility inquiry focuses on whether the expert’s specialized knowledge and methods are sufficiently reliable and helpful to the jury.
- Expert testimony may be admitted to explain behavior of domestic-violence victims (including recantation) that jurors might otherwise find inconsistent with credibility, so long as it assists the factfinder rather than substituting for it.
- In clinical and forensic contexts, an expert may rely on professional experience, relevant literature, interviews, and review of case records; imperfections in investigation typically are addressed through cross-examination and competing evidence.
- The timing of an interview and the choice not to interview additional collateral witnesses generally affect the persuasiveness of the opinion, not whether it meets the minimum admissibility threshold.

## Conclusion

The Seventh Circuit upheld Young’s domestic-violence convictions, concluding that the district court permissibly admitted expert testimony explaining victim recantation because the expert was well-qualified, used an acceptably reliable clinical and case-specific methodology, and offered testimony aimed at helping the jury interpret the victim’s changed account.


United States v. Young, 316 F.3d 649 (7th Cir. 2002)