State of Arizona v. Mark Haskie, Jr., 242 Ariz. 582

Mark Haskie was charged with multiple felony counts after assaulting his girlfriend, P.J.; physical evidence and an initial statement by P.J. corroborated the assault.
Nearly a year later P.J. sent letters recanting and at trial testified she did not remember the assault due to drinking and implicated herself in infidelity.
The State sought to admit "cold" expert testimony from Dr. Kathleen Ferraro about typical domestic-violence victim behavior (recantation, returning to abusers, self-blame) to explain P.J.’s inconsistent statements and reluctance to testify.
The trial court limited Dr. Ferraro’s testimony to specific questions; Ferraro did not review case-specific evidence or directly link her testimony to Haskie’s conduct.
The jury convicted Haskie on multiple counts; the court of appeals affirmed but the Arizona Supreme Court granted review on whether Ferraro’s testimony was impermissible offender profiling.
The Supreme Court held the testimony admissible: it aided jurors in understanding victim behavior, was relevant and more probative than prejudicial, and did not implicitly invite conviction based on a profile.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dr. Ferraro’s "cold" expert testimony constituted impermissible profile evidence	State: Testimony explains victim behavior and is admissible under Rule 702; it does not tie to Haskie and aids jury evaluation of credibility	Haskie: Testimony functioned as impermissible profile/vouching and invited jury to infer guilt from characteristics	Court: Admissible — testimony was general, explained victim behavior, not tied to Haskie, and probative value outweighed prejudice
Standard for identifying impermissible profile evidence from expert testimony	State: Impermissible only if prosecution establishes a common profile, lists components, and expressly compares defendant to the profile	Haskie: Broader scrutiny is required; implicit profiling can be prejudicial without explicit comparison	Court: Rejected bright-line test; trial courts must assess prejudicial effect of the testimony as a whole under Rules 401, 402, 403, 702 and may exclude or limit testimony that effectively creates a profile

State v. Salazar-Mercado, 234 Ariz. 590 (explaining admissibility of "cold" expert testimony about general victim behavior)
State v. Ketchner, 236 Ariz. 262 (holding cold-expert testimony inadmissible where it invited jury to infer defendant’s guilt by comparing him to offender characteristics)
State v. Moran, 151 Ariz. 378 (expert testimony about victim behavior may aid credibility and be admissible)
State v. Lee, 191 Ariz. 542 (discussing limits on using profile evidence as substantive proof of guilt)
Ryan v. State, 988 P.2d 46 (Wyo.) (warning that even implicit invitations to infer guilt from characteristics demand close scrutiny)