Rachelle S. v. Ariz. Dep't of Econ. Sec
In Rachelle S. v. Ariz. Dep't of Econ. Sec., 191 Ariz. 518, 520,12, 958 P.2d 459, 461 (App. 1998), a child had been removed from his parents after suffering a severe head injury. 191 Ariz. at 519,8, 958 P.2d at 460.
At issue during the dependency trial were the cause of the trauma the child suffered and whether the child would suffer additional abuse if he were returned to his parents. Id. at 521,15, 958 P.2d at 462.
The child's attending physician testified the child likely was a victim of shaken-baby syndrome. Id. at 519,6, 958 P.2d at 460.
The Court held the physician qualified as an expert witness pursuant to 25 U.S.C. 1912(f) because he had knowledge and experience regarding shaken-baby syndrome and because the likelihood of future abuse did not implicate any "cultural dictate or explanation." Id. at 521,15, 958 P.2d at 462.