Estelle v. McGuire,
502 U.S. 62 (1991).



Facts: McGuire (D) was convicted by circumstantial evidence of the second-degree murder of his infant daughter, who died of multiple injuries to her vital organs. At trial, testimony indicated that her injuries were consistent with the type of injury often sustained as a result of the "battered child syndrome," a condition where it is determined that a child's injuries most likely did not occur as a result of an accident. Further testimony indicated that D had had exclusive control of the child during the time that the injuries most likely took place. There was evidence that while his wife and he were at the hospital where the child died, she accused him of causing the death. On prior occasions she had expressed fear of leaving the child alone with D. A neighbor had seen him treat the baby roughly. At trial D's wife stated she had beaten the baby before her husband had arrived at home. This testimony was in contrast to her statement to the police and her conversation at the hospital that she had not injured the child. D appealed from the judgment of conviction. The California Court of Appeals affirmed the conviction, observing that the evidence of prior rib and rectal injuries was introduced to prove "battered child syndrome" and was proper. The Supreme Court of California denied review.

Issues:

1. Is establishment of the existence of a battered child, together with the reason-able inference of a battering parent, sufficient to convict the parent of second- degree murder without violating due process?
2. Was the instruction to the jury sufficient to allow the jury to consider the prior injuries only for proof of the battered child syndrome and not as a direction to the jury to find that D had committed these prior acts and that he had the propensity to commit this type of crime, for which he was charged?

Holding:On certiorari, the Supreme Court, Chief Justice Rehnquist, held that:1) evidence that infant victim suffered from battered child syndrome was relevant to establish intent; (2) jury instruction on prior injury evidence did not improperly direct jury to find that defendant had caused prior injuries; and (3) jury instruction did not constitute “propensity” instruction.
Reversed.


AnalysisOn review of the warden's petition for writ of certiorari, the United States Supreme Court held that none of the alleged errors rose to the level of due process violations. In so holding the Court concluded that (1) the circuit court improperly examined violations of state law governing the admission of evidence; (2) the evidence of prior injuries presented at trial, whether directly linked to the inmate or not, was probative on the question of the intent with which the person who caused the injuries acted and therefore admissible; and (3) as this evidence was relevant to show intent, nothing in the Due Process Clause of the Fourteenth Amendment required the State to refrain from introducing evidence of prior injuries simply because the defense chose not to raise the defense of accidental death.