United States v. Bostick

33 M.J. 849, 1991 CMR LEXIS 1337, 1991 WL 226490
CourtU.S. Army Court of Military Review
DecidedOctober 30, 1991
DocketACMR 9001520
StatusPublished
Cited by2 cases

This text of 33 M.J. 849 (United States v. Bostick) is published on Counsel Stack Legal Research, covering U.S. Army Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Bostick, 33 M.J. 849, 1991 CMR LEXIS 1337, 1991 WL 226490 (usarmymilrev 1991).

Opinion

OPINION OF THE COURT

HOWELL, Judge:

A military judge sitting as a general court-martial at Fort Hood, Texas, convicted the appellant, contrary to his pleas, of attempted sodomy, indecent assault, false swearing, and communicating a threat in violation of Articles 80 and 134, Uniform Code of Military Justice, 10 U.S.C. §§ 880 and 934 (1982), respectively. The appellant’s adjudged sentence included a bad-conduct discharge, confinement for seven years, forfeiture of $200 pay per month for eighty-four months, and reduction to Private El. The convening authority approved the sentence.

Before this court, the appellant has assigned five errors through counsel and has personally asserted additional matters for consideration pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A.1982). We will address only the contention that the military judge committed reversible error by admitting and soliciting certain expert testimony.

I.

Factual Background

During the government’s case-in-chief, the victim, SPC B, testified that she first met the appellant through a mutual friend, SPC W, one day prior to the incident. The three made plans to go bowling the next day, a Saturday. At the last minute SPC W became ill and could not go, but the appellant and SPC B went bowling together anyway in Killeen, near Fort Hood. Returning directly to Fort Hood early Saturday evening, they visited SPC W briefly, and then went to SPC B’s room so the appellant could use her tape player. According to SPC B, once the two were alone in the room, the appellant began to make sexual advances toward her. He then threw her on a bed and attempted to rape and orally sodomize her. When SPC B resisted, the appellant abandoned his efforts after a brief period of time. Before leaving the room, he threatened to kill SPC B if she told anyone about the incident. SPC B testified further, that during the attack she did not scream nor call out. Moreover, she was not struck by the appellant, nor did she suffer any physical injury. After the appellant departed, she remained all night in a common area adjacent to her room, scared and crying. She did not report the incident to the authorities until the next morning, after talking to a friend who stopped by her room.

During the defense case-in-chief, the appellant told a different story. He acknowledged going bowling with SPC B and returning to her barracks room early that evening. However, he contended that he then went to a friend’s house to watch television. He denied having any sexual [851]*851contact with SPC B and specifically denied sexually assaulting or threatening her.

II.

Expert Testimony

To establish a foundation for later expert testimony, the trial counsel questioned SPC B about the after-effects she suffered as a result of the incident. SPC B responded that she had trouble sleeping and eating, experienced nightmares and episodes of crying, no longer socialized as much as before the incident, and was afraid to be alone. Additionally, the trial counsel called SPC B’s platoon sergeant and her platoon leader who testified that after the alleged incident they observed severe behavioral changes in SPC B.

Ms. Patricia LaRochelle, Sexual Assault Program Coordinator at the Killeen Rape Crisis Center, testified for the government. Over defense objection she was recognized as an expert in “sexual assault counseling.” (R. 90). Ms. LaRochelle testified that she interviewed and otherwise assisted SPC B on 7 March 1990, four days after the alleged assault. She described SPC B on that occasion as shaken, withdrawn, and able to talk about the incident only with difficulty. In Ms. LaRochelle’s opinion, based on her observations, the interview, and her past experience and knowledge, SPC B’s behavior at the time of the interview was consistent with behavior she had observed in other sexual assault victims and behavior reported “in the literature.” (R. 101). In response to questions from the military judge, Ms. LaRochelle acknowledged that she did not question SPC B’s veracity, nor did she administer any psychological tests. She concluded, however, that “obviously ... in my opinion, she had been traumatized.” (R. 103).

Dr. Michael Campbell, a psychologist in private practice in Killeen, testified for the government. The court recognized Dr. Campbell as an expert in “the diagnosis and treatment of female sexual assault victims, rape trauma syndrome, and post-traumatic stress disorders.” (R. 112). The trial defense counsel objected only to his expertise in rape trauma syndrome. During direct examination, Dr. Campbell defined post-traumatic stress disorder (PTSD), described the relationship of rape trauma syndrome to PTSD, and concluded that attempted rape or sodomy could lead to PTSD. He testified that he generally based his diagnosis of PTSD on the results of a clinical interview, which included a Rape Aftermath Symptoms Test, and sometimes other psychological tests.

Dr. Campbell testified that he first examined SPC B on 9 May 1990, more than two months after the alleged assault. Thereafter, he observed her behavior both in his office and in a group counseling session, interviewed her for four to five hours over a three-day period, and administered a Rape Aftermath Symptoms Test. His diagnosis was that SPC B was suffering from PTSD and rape trauma syndrome. Without defense objection, the trial counsel asked Dr. Campbell during direct examination whether he believed “... that the criteria and symptoms that you’ve identified have been faked by [SPC B].” Dr. Campbell responded, “No, I don’t believe that at all.” (R. 117). In response to further questioning by the trial counsel, Dr. Campbell described the Rape Aftermath Symptoms Test he administered to SPC B:

Yes, it’s a test [consisting of] lists of symptoms and the patient is asked to rate the severity with which they experience these things. For example, is it especially alarming to the woman to go into an empty parking lot, or to get on an elevator alone, or to walk into a room where everyone is sitting down; now, some of these things don't have any obvious relationship to sexual assault, but the developers of the test have empirically demonstrated that women who have been sexually assaulted tend to be more reactive to these situations. The average score for a woman who has been sexually assaulted, within one month of her sexual assault, usually scores slightly over 100 out of a possible 280 points. A woman who has never been sexually assaulted usually scores around 40. [SPC B] scored 196. (R. 118).

[852]*852During examination of Dr. Campbell by the court, the military judge immediately addressed the Rape Aftermath Symptoms Test and its relation to the purported victim’s credibility. Again there was no defense objection to this line of questioning.

Q: Okay now, the purpose of this test is to extract information and data from the victim, right?
A: Yes, sir.
Q: Would you, by any chance, have a copy of that test with you?
A: No, sir, not with me.
Q: Okay. Describe for me, if you would ... so that I fully understand this test ... exactly what type of test it is; what information it seeks to obtain from the victim.

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Cite This Page — Counsel Stack

Bluebook (online)
33 M.J. 849, 1991 CMR LEXIS 1337, 1991 WL 226490, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-bostick-usarmymilrev-1991.