State v. Haskie, 240 Ariz. 269

Defendant Mark Haskie was charged and convicted of multiple domestic-violence offenses (aggravated assault, aggravated domestic violence, influencing a witness, kidnapping) after a 911 call and physical evidence from a motel where the victim, P.J., had visible injuries.
P.J. initially gave a written statement to police saying Defendant beat and strangled her; physical evidence (belt, strap, bloodied pillows, DNA) corroborated injuries.
Nearly a year later, after Defendant’s arrest, P.J. wrote letters recanting and claimed she had been drinking and fabricated the incident; she also testified at trial that she loved Defendant and didn’t recall details due to alcohol.
The State called Dr. Kathleen Ferraro as a “cold” expert on domestic violence to explain victim behavior such as returning to abusers, recantation, and victim self-blame; the court limited her testimony to general victim behaviors and approved specific questions.
Dr. Ferraro testified generally about why victims minimize, recant, or assist abusers; on cross-examination she stated fabrication of an initial report is "very rare," which the court later deemed vouching in part.
Defendant preserved his pretrial objection to Dr. Ferraro’s testimony for appeal; the court found most of the testimony admissible, but some statements improperly vouched for victim credibility. The court nevertheless held any error was harmless given overwhelming evidence and affirmed convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility: expert testimony on domestic-violence victim behavior	State: Expert may explain counterintuitive victim behavior to aid jury understanding	Haskie: Testimony is impermissible offender profiling/vouching and should be excluded	Testimony explaining general victim behaviors admissible; did not constitute profiling because it did not describe an offender profile
Offender profiling	State: Testimony described victim behavior, not abuser characteristics	Haskie: Testimony implicitly profiled him as an abuser (Ketchner bar)	Distinguishable from Ketchner; testimony focused on victim conduct and was not used as substantive proof of guilt
Vouching / credibility opinion	State: Expert can explain why recantation is consistent with abuse; limits apply	Haskie: Expert improperly vouched by saying false initial reports are "very rare" and thus vouched for P.J.	Court: Portion of testimony stating fabrication is "very rare" constituted improper vouching, but most general testimony was permissible
Harmless error	State: Any improper vouching was harmless due to strong independent evidence	Haskie: Improper credibility testimony likely affected jury verdict	Court: Error harmless beyond a reasonable doubt given corroborating physical evidence, recordings, jury instruction on experts, and prosecutor's limited use of the testimony

State v. Ketchner, 236 Ariz. 262 (superseding authority on limits of profile evidence in domestic-violence context)
State v. Tucker, 165 Ariz. 340 (expert may testify about general victim/defendant behavior when beyond lay knowledge)
State v. Moran, 151 Ariz. 378 (expert may explain recantation factors but may not opine on a witness’s veracity)
State v. Lindsey, 149 Ariz. 472 (expert improperly vouched by expressing belief that abuse likely occurred)
State v. Herrera, 232 Ariz. 536 (permitted expert testimony where expert had no knowledge of case specifics)
State v. Salazar-Mercado, 234 Ariz. 590 (discusses limits on case-specific expert opinions)
State v. Burton, 144 Ariz. 248 (pretrial motion in limine preserves objection for appeal)
State v. Henderson, 210 Ariz. 561 (harmless error standard)
State v. Anthony, 218 Ariz. 439 (overwhelming evidence can render error harmless)
State v. Crane, 166 Ariz. 3 (harmless-error analysis supporting affirmance)
State v. LeBlanc, 186 Ariz. 437 (presumption that jury follows limiting instructions)