State v. Hanks, 2012 Minn. LEXIS 386

Betsy Hanks killed her romantic partner, Matthew Albert, in 2009; she and Albert had a troubled, controlling relationship.
Hanks lived with Albert for years, had four children, and faced financial and social isolation under his control.
Hanks had a developing relationship with L.G.; the State alleged an affair, and Albert opposed it and threatened consequences.
Before trial, Hanks received funding for a battered woman syndrome expert, which the district court later barred from testifying.
Hanks was tried and convicted of both first-degree and second-degree murder; the court later vacated the second-degree conviction on appeal.
The court ultimately affirmed the first-degree murder conviction, reversed the second-degree conviction, and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of battered woman syndrome testimony	Hanks argues the expert is relevant to explain id.	Hanks maintains the testimony clarifies behavior and premeditation.	Exclusion of battered woman syndrome testimony was not reversible error.
Admission of threats/bruises evidence and related credibility	Hanks contends exclusion deprived her defense and intent.	State contends rulings were narrow and did not bar her testimony.	No abuse of discretion; defense could still explain relationship and conduct.
Right to present a complete defense	Hanks claims the rulings prevented full explanation of intent and motives.	State argues court allowed substantial explanation of relationship and conduct.	No violation of a complete defense; evidentiary rulings were within discretion.
Convictions for first- and second-degree murder for same act	Dual convictions for the same act against the same victim were improper.	State contends both counts survived merger analysis in prior precedent.	Conviction for second-degree murder vacated; only first-degree murder conviction sustained.

State v. Hennum, 441 N.W.2d 793 (Minn. 1989) (admissibility of battered woman syndrome in self-defense context; credibility and imminence)
State v. Grecinger, 569 N.W.2d 189 (Minn. 1997) (battered woman syndrome to explain why victim remains with abuser and recants)
State v. MacLennan, 702 N.W.2d 219 (Minn. 2005) (insufficient relationship evidence for battered woman syndrome; relevance test)
State v. Richards, 495 N.W.2d 187 (Minn. 1992) (right to call witnesses; evidentiary rulings reviewed for abuse of discretion)
State v. Brechon, 352 N.W.2d 745 (Minn. 1984) (defendant's right to explain conduct under defense-friendly evidentiary rules)
State v. Pippitt, 645 N.W.2d 87 (Minn. 2002) (merger/dual conviction limitations for same act against same victim)