Estelle v. McGuire

In Estelle v. McGuire. 502 U.S. 62, 68-69, 116 L. Ed. 2d 385, 112 S. Ct. 475 (1991), the defendant was charged with murdering his infant daughter. The defendant told police that the child's fatal injuries must have resulted from a fall off the family couch or that "maybe some Mexicans came in" and did it while he was upstairs. The prosecution then introduced evidence that the child had suffered numerous earlier injuries, as well as expert testimony regarding "battered child syndrome." The defendant objected, stating that the prosecution had failed to show that he had inflicted any of the earlier injuries or that those injuries were intentionally inflicted. According to the Supreme Court: evidence demonstrating battered child syndrome helps to prove that the child died at the hands of another and not by falling off a couch for example; it also tends to establish that the "other," whoever it may be, inflicted the injuries intentionally. When offered to show that certain injuries are a product of child abuse, rather than accident, evidence of prior injuries is relevant even though it does not purport to prove the identity of the person who might have inflicted those injuries.