Justia Civil Rights Opinion Summaries

Dagoberto Machado was convicted by a jury of multiple offenses related to the inappropriate touching of I.A., his girlfriend’s young niece. The incidents allegedly occurred during the summers of 2016 and 2017 when I.A. was staying with Machado and his girlfriend. I.A. testified that Machado touched her inappropriately on several occasions, including at a public pool and in their home. She did not immediately report the incidents due to uncertainty and fear of affecting family relationships. The government introduced expert testimony from Dr. Stephanie Wolf, a child psychologist, to provide context for I.A.'s delayed reporting, including cultural barriers within Latino communities.The Superior Court of the District of Columbia admitted Dr. Wolf’s testimony over Machado’s objections. Machado argued that Dr. Wolf’s statements about “machismo” in Latino culture were prejudicial. The trial court qualified Dr. Wolf as an expert and allowed her to testify about cultural norms that might impede a child from disclosing abuse. Dr. Wolf mentioned that in Latino culture, men might have a higher standing, which could impact how sexuality and abuse are viewed. The jury found Machado guilty on all counts.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred in admitting Dr. Wolf’s testimony about Latino culture. The court held that the testimony had minimal probative value and was substantially outweighed by its potential to unfairly prejudice the jury against Machado based on ethnic stereotypes. The court emphasized that such testimony could lead the jury to view Machado as more likely to have committed the abuse simply because of his ethnicity. Consequently, the court reversed Machado’s convictions and remanded the case for further proceedings. View "Machado v. United States" on Justia Law