Dealing with 'Diaz': How Defendants Can Combat and Use Expert Testimony Regarding Group Mental State
Quinn Emanuel partners Michael Packard and Daniel Koffmann discuss the recent decision in 'Diaz v. United States,' where the Supreme Court has given prosecutors the green light to prove defendants' criminal intent by offering expert testimony about the mental state of people "like" the defendant.
September 04, 2024 at 10:00 AM
13 minute read
EvidenceThe Supreme Court recently gave prosecutors a green light to prove defendants' criminal intent vicariously, by offering expert testimony about the mental state of people "like" the defendant.
At the tail end of its recent term, the court held in Diaz v. United States that while Rule 704(b) of the Federal Rules of Evidence prohibits an expert from testifying that a particular defendant had a culpable state of mind when engaged in allegedly criminal conduct, that rule does not bar an expert from testifying that "most people" have a guilty mental state when they engage in the same activity.
"The upshot," observed the dissenting justices, is that "[p]rosecutors can now put an expert on the stand—someone who apparently has the convenient ability to read minds—and let him hold forth on what 'most' people like the defendant think when they commit a legally proscribed act. Then, the government need do no more than urge the jury to find that the defendant is like 'most' people and convict." In so holding, Diaz put "a powerful new tool in the government's pocket."
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