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State Of Washington, V Hector Francisco Saavedra Ruiz
47572-3
| Wash. Ct. App. | Dec 20, 2016
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Background

  • 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 Saavedra Ruiz: Experts relied on outdated/misleading shaken-baby science, requiring reversal. State: The record contains no evidence that testimony was misleading or scientifically outdated; prosecution did not rely on shaking theory as the sole cause.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On direct appeal, claim fails because review is limited to the trial record and nothing in the record shows misleading/outdated expert testimony; conviction affirmed.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)
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Case Details

Case Name: State Of Washington, V Hector Francisco Saavedra Ruiz
Court Name: Court of Appeals of Washington
Date Published: Dec 20, 2016
Docket Number: 47572-3
Court Abbreviation: Wash. Ct. App.