State Of Washington, V Hector Francisco Saavedra Ruiz
47572-3
| Wash. Ct. App. | Dec 20, 2016Background
- Infant Natalie died days after visiting her father, Hector Saavedra Ruiz; autopsy and hospital exams showed a skull fracture, subscalp bleeding, retinal hemorrhages, and brain injury.
- Paramedics revived Natalie but she was transferred to Mary Bridge Children’s Hospital and died three days later.
- The State charged Saavedra Ruiz with second-degree murder alleging he caused Natalie’s death during or in furtherance of child assault; aggravators included family relationship, victim vulnerability, and position of trust.
- Medical experts testified for the State that Natalie's injuries were from blunt force trauma, that retinal findings correlated with shaking, and that symptoms would appear immediately after severe head injury.
- At closing, the State argued the injuries resulted from being slammed against a surface (blunt force), not solely from shaking; the jury convicted Saavedra Ruiz of second-degree murder and found the special verdicts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did presentation of expert testimony about shaken-baby science violate due process/fair trial rights? | Saavedra Ruiz: Experts relied on outdated/misleading shaken-baby science, requiring reversal. | State: The record contains no evidence that testimony was misleading or scientifically outdated; prosecution did not rely on shaking theory as the sole cause. | Court: On direct appeal, claim fails because review is limited to the trial record and nothing in the record shows misleading/outdated expert testimony; conviction affirmed. |
Key Cases Cited
- In re Pers. Restraint of Fero, 192 Wn. App. 138 (2016) (postconviction relief granted where extra-record expert declarations showed a paradigm shift undermining medical testimony at trial)
- State v. McFarland, 127 Wn.2d 322 (1995) (personal restraint petitions permit consideration of matters outside the trial record)
