Scadden v. State

In Scadden v. State, 732 P.2d 1036 (Wyo. 1987), a case involving molestation of high schoolers by their teacher, although the admissibility of rape trauma syndrome testimony was challenged, the Court did not need to reach the issue for decision of the case: "Detective Reikens' expert testimony was not testimony regarding rape-trauma syndrome, and therefore we do not now decide whether such testimony is admissible. In any event, the admissibility of rape-trauma testimony must be carefully confined to avoid jury convictions based not on what the direct evidence shows occurred, but on expert opinion." Scadden v. State, 732 P.2d at 1047. The Court went on to hold the expert's testimony admissible to explain the behavioral characteristics of the victims. 732 P.2d at 1046-47. The Scadden court stated that this kind of testimony may play a particularly useful role by disabusing the jury of some widely held misconceptions about rape and rape victims, so that it may evaluate the evidence free of the constraints of popular myths. 732 P.2d at 1047.