Sorensen v. State

In Sorensen v. State, 895 P.2d 454 (Wyo. 1995), at issue was the admissibility of testimony on the theory of traumagenic dynamics, a model that "postulates that the experience of sexual abuse can be analyzed in terms of four trauma-causing factors." 895 P.2d at 457. After a review of two articles in professional journals, this court concluded, due to the paucity of information on the subject and the fact that even the theory's own proponents conceded "few theoretical advances" had been made, that traumagenic dynamics was not sufficiently developed to the point it could be considered reliable in its field. 895 P.2d at 458. "Unless and until such time as evidence can be brought forth which demonstrates to the contrary, traumagenic dynamics is inadmissible in the courts of Wyoming." Id. The Sorensen court concluded discussion of this issue by writing, "The State may certainly continue to offer this type of evidence, but it may not wrap its evidence up in the cloak of a 'theory' or a 'syndrome' unless it has been established as reliable." 895 P.2d at 459.