State v. Goff
128 Ohio St. 3d 169
| Ohio | 2010Background
- Defendant Megan Goff killed her estranged husband William Goff, firing 15 shots in his home and asserting battered-woman syndrome in self-defense.
- State sought to rebut imposed self-defense evidence by ordering a psychiatric examination by the State's expert Dr. Phillip Resnick.
- Trial court allowed the State's examination if the defense presented experts; Goff objected.
- Resnick conducted extensive in-person and follow-up interviews, producing a 35-page report.
- Goff was tried to a visiting judge; the State's expert testified, including analysis of inconsistencies between Goff's statements and evidence.
- Court of appeals held Goff's invocation of her own psychiatric defense waived self-incrimination; Ohio Supreme Court granted discretionary appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether compelled psychiatric examination violates self-incrimination | Goff | Goff | No, generally permissible; but limits apply |
| Whether battered-woman syndrome alone can justify examination without violating rights | State | Goff | State may compel to rebut defense when syndrome is central to self-defense |
| What limits govern the state's expert testimony | State | Goff | Testimony must focus on syndrome and its effect; not recount unwarned statements |
| Whether Resnick exceeded his role by evaluating credibility and inconsistencies | State | Goff | Resnick exceeded proper scope; violated self-incrimination rights |
| Whether the examination was properly authorized by statute | State | Goff | Compelling examination not authorized absent statutory provision; decision reversed |
Key Cases Cited
- State v. Koss, 49 Ohio St.3d 213 (1990) (battered-woman syndrome admissible to prove self-defense element)
- Estelle v. Smith, 451 U.S. 454 (1981) (psychiatrist testimony during penalties violated Fifth Amendment)
- Manning, 74 Ohio App.3d 19 (1991) (state may compel independent examination when mental state is at issue)
- Buchanan v. Kentucky, 483 U.S. 402 (1987) (prosecution may rebut psychiatric defense with own testimony)
- In re Estelle; United States v. Byers, Byers, 239 U.S.App.D.C. 1, 740 F.2d 1104 (1984) (discussed limits on defendant's privilege with psychiatric evidence)
- State v. Hickson, 630 So.2d 172 (1993) (state examination depends on type of battered-woman syndrome testimony)
- State v. Briand, 130 N.H. 650 (1988) (defendant waives privilege when testifying indirectly through an expert)