State v. Martin

¶1 Under ER 702, opinion testimony by an expert witness must be based on a theory generally accepted in the scientific community. Here, the trial court conducted a Frye1 hearing and determined that the betrayal trauma theory espoused by the defendant’s expert was not generally accepted in the scientific community and, *623further, that even if the theory met the Frye standard for delayed reporting of childhood sexual abuse, it was not established as a theory relevant to adult domestic violence and thus not particularly helpful to the issue of intent in a domestic violence case. The trial court is…