Exclusion of Extrinsic Expert Evidence on Credibility Did Not Violate Criminal Defendant's Due Process Rights, Says Minnesota Supreme Court

The Minnesota Supreme Court has ruled that a criminal defendant's constitutional right to present a defense was not violated when the trial court excluded the defendant's expert evidence about the effects of a victim's glue-sniffing habit on the victim's ability to process information. The trial court had been prepared to allow expert testimony about the effects of glue-sniffing in general, but not the expert's opinion about its effects on the witness in particular. The latter kind of testimony is legitimately impermissible, because it would represent expert testimony about ultimate facts surrounding the witness's credibility, according to the opinion. See State v. Reese, No. A03-1887 (Minn. Mar. 3, 2005).