📄 Cross-examination of Dr. Donald Dutton (part 1) — Thursday, January 12, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JAN\12\CROSS-EXAMINATION-OF-DR-DONALD.DOC
TRIAL
▲ Day 2 of 167

Cross-examination of Dr. Donald Dutton (part 1)

Witness: Dr. Donald Dutton
Examiner: F. Lee Bailey
Called by: Prosecution • Date: Thursday, January 12, 1995 • Utterances: 440
F. Lee Bailey cross-examines prosecution domestic violence expert Dr. Donald Dutton in a pre-trial admissibility hearing. Bailey methodically uses Dutton's own professional framework — APA ethics standards, Dr. Lenore Walker's battered woman checklist, and Dutton's own research — to establish that Dutton never examined Simpson, cannot ethically opine on him, and that several of Simpson's documented behaviors (generous financial giving, equanimity upon learning of Nicole's sexual activity, non-reaction to her late-night hours) are inconsistent with classic batterer syndrome. The examination ends on an unexpectedly warm note with Dutton offering to FedEx Bailey autographed copies of his books.
1 THE COURT:

MR. BAILEY.

2

CROSS-EXAMINATION

3

BY MR. BAILEY:

4 Q:

DR. DUTTON, WHEN WERE YOU FIRST ENGAGED IN THIS CASE BY THE STATE?

5 MR. GORDON:

OBJECTION, RELEVANCE, YOUR HONOR.

6 THE COURT:

OVERRULED. YOU CAN ANSWER THE QUESTION.

7 DR. DONALD DUTTON:

DECEMBER, 1994.

8 Q:

BY MR. BAILEY: ALL RIGHT. AND YOU HAVE BEEN SITTING HERE DURING THE DAY AND A HALF OF HEARINGS THAT HAVE PRECEDED YOUR ARRIVAL ON THE WITNESS STAND, HAVE YOU NOT?

9 A:

YES, I HAVE.

10 Q:

AND YOU HAVE LISTENED TO A SERIES OF ALLEGED INCIDENTS PORTRAYED BY THE PROSECUTION?

11 A:

YES.

12 Q:

HAVE YOU STUDIED ANY ADDITIONAL MATERIALS RELEVANT TO THE CASE BEFORE COMING HERE TODAY?

13 A:

YES. I LOOKED AT AN EVIDENCE BOOK THAT HAD BEEN PROVIDED.

14 Q:

ALL RIGHT. IS THAT CALLED THE MURDER BOOK, DO YOU KNOW?

15 A:

I HADN'T HEARD THAT TERM USED, BUT --

16 Q:

SOME BOOK WITH EVIDENCE IN IT?

17 A:

YEAH. A GREEN BOOK WITH EVIDENCE IN IT; THAT'S RIGHT.

18 Q:

HAVE YOU LOOKED AT ANYTHING OTHER THAN DOCUMENTS?

19 MR. GORDON:

OBJECT ON RELEVANCE GROUNDS.

20 THE COURT:

OVERRULED.

21 DR. DONALD DUTTON:

UMM, I HAVE LOOKED AT THE DEFENSE AND PROSECUTION BRIEFS.

22 Q:

BY MR. BAILEY: TO JUDGE ITO ON THIS ISSUE?

23 A:

YES.

24 Q:

ON THIS ISSUE?

25 A:

YES.

26 Q:

THEN YOU HAVE NOTICED OF COURSE THAT WITHIN THE PAGES OF THE PROSECUTION'S BRIEF IS THE DULUTH, MINNESOTA, POWER AND CONTROL WHEEL?

27 A:

YES.

28 Q:

IS THAT SOMETHING TO WHICH YOU MAKE REFERENCE IN YOUR PRACTICE?

29 A:

YEAH, WE MAKE -- WE DO MAKE REFERENCE TO IT IN OUR PRACTICE, YES.

30 Q:

YOU HAVE SAID THAT SYNDROMES OF THIS TYPE INVOLVE ALL ASPECTS OF ATTEMPTS TO CONTROL THE VICTIM BY THE BATTERER, TRUE?

31 A:

YES, YES.

32 Q:

OKAY. ARE YOU AFFILIATED WITH OR FAMILIAR WITH THE AMERICAN PSYCHOLOGICAL ASSOCIATION?

33 A:

YES, I AM.

34 Q:

DO YOU ATTEND THEIR MEETINGS?

35 A:

I AM A MEMBER OF THE AMERICAN PSYCHOLOGICAL ASSOCIATION.

36 Q:

ALL RIGHT, FINE. YOU ARE AWARE OF THE REQUIREMENT IN THE AMERICAN PSYCHOLOGICAL ASSOCIATION THAT FOR A PSYCHOLOGIST TO GIVE AN OPINION RELATING TO AN INDIVIDUAL, A PERSONAL EXAMINATION IS NECESSARY?

37 A:

RIGHT.

38 Q:

TRUE?

39 A:

YES.

40 Q:

HAVE YOU EVER EXAMINED MR. SIMPSON?

41 A:

NO, I HAVE NOT.

42 Q:

HAVE YOU EVER ASKED THE DEFENSE IF THEY HAD ANY COUNTERVAILING EVIDENCE WITH RESPECT TO THE PROFFER YOU HAVE HEARD THAT WOULD TEND TO CAST DOUBT UPON THE INCIDENTS ALLEGED?

43 A:

NO, I HAVE NOT.

44 Q:

OKAY. DID ANYBODY GIVE YOU THE GRAND JURY TESTIMONY OF A MAN NAMED KEITH ZLOMSOWITCH?

45 A:

I HAVE READ THAT.

46 Q:

YOU HAVE READ IT?

47 A:

YES.

48 Q:

OKAY. IF MR. SIMPSON HAD BEEN SENT TO YOU IN THE ORDINARY COARSE OF YOUR PRACTICE --

49 A:

UH-HUH.

50 Q:

-- THAT WOULD PROBABLY HAVE BEEN AS A RESULT OF THE ORDER OF A JUDGE OR BECAUSE HE FELT HE HAD A PROBLEM AND WANTED YOUR HELP?

51 A:

THAT'S CORRECT.

52 MR. GORDON:

CALLS FOR SPECULATION AND IS IRRELEVANT, YOUR HONOR.

53 THE COURT:

OVERRULED.

54 Q:

BY MR. BAILEY: HAVE YOU FREQUENTLY BEEN CALLED UPON TO GIVE OPINION IN CASES WHERE YOU'VE HAD NO CONTACT WITH EITHER OF THE SUBJECTS?

55 A:

I WOULDN'T SAY FREQUENTLY. I HAVE OCCASIONALLY BEEN.

56 Q:

ALL RIGHT.

57 A:

YES.

58 Q:

WOULD YOU AGREE THAT IN ORDER TO HAVE A BATTERER IT IS NECESSARY TO HAVE A BATTERED WOMAN ON THE OTHER SIDE?

59 A:

YES.

60 Q:

OKAY. DO YOU KNOW OF ANY INSTANCE WHERE NICOLE BROWN SIMPSON, THE DECEDENT, WAS EVER DESCRIBED AS OR DIAGNOSED AS A BATTERED WOMAN?

61 A:

DIAGNOSED, NO.

62 Q:

DID SHE EVER GET ANY TREATMENT THAT YOU KNOW OF?

63 A:

NOT TO MY KNOWLEDGE.

64 MR. GORDON:

OBJECT, YOUR HONOR. THIS GOES BEYOND THE SCOPE OF THIS HEARING AND IT GOES BEYOND THE SCOPE OF THE TESTIMONY THAT HAS BEEN PRESENTED.

65 THE COURT:

WE ARE BEYOND THE SCOPE OF HIS EXPERT TESTIMONY IN A GENERAL SENSE. YOU ARE GOING INTO SPECIFICS REGARDING THIS CASE. DO YOU REALLY WANT TO GET INTO THAT?

66 MR. BAILEY:

MAY I SUGGEST THIS, YOUR HONOR? I GATHER THAT WHAT THE PROSECUTION IS INVITING THE COURT TO DO IS TO SAY THAT EVEN IF INADMISSIBLE ON OTHER GROUNDS AS PART OF A SYNDROME, THESE ACTS SHOULD BE KNITTED TOGETHER AND THEREFORE COME IN. IF I AM MISTAKEN, I'M SURE I WILL BE CORRECTED, BUT I HAVE REASON TO BELIEVE THAT IS WHAT COUNSEL IS ABOUT. IN ORDER TO ASSESS WHETHER OR NOT YOU WOULD WANT TO MAKE SUCH A RULING AND THE PERIL THAT YOU MIGHT HAVE TO STRIKE IT LATER ON IF THE FACTS TURNED OUT TO BE DIFFERENT, I SIMPLY WOULD LIKE TO TEST THE SITUATION WITH THIS EXPERT.

67 MR. GORDON:

MAY I RESPOND, YOUR HONOR?

68 THE COURT:

YES.

69 MR. GORDON:

AND I DO FEEL IT A HONOR TO BE ABLE TO STAND UP IN COURT AND DISAGREE WITH MR. BAILEY. IN THEIR BRIEF THE DEFENSE BROUGHT FORTH A SOCIAL SCIENCE ARGUMENT BASED ON, AS WE SAW IN COURT LAST WEEK, WE DON'T KNOW WHAT EMPIRICAL DATA, AND IN THEIR BRIEF AND IN THEIR ARGUMENT AND IN MR. UELMEN'S ARGUMENT THEY HAVE ASKED THIS COURT TO MAKE FINDINGS SPECIFICALLY LINKED TO THAT ARGUMENT, NOT AS TO THE SPECIFICS OF THIS CASE, BUT AS TO THIS -- THAT ARGUMENT. WE ARE PRESENTING EVIDENCE, I HAVE BEEN ARGUING TO THIS COURT FOR THE PAST TWO DAYS, WITH REGARD TO THE IMPORTANCE OF THAT ARGUMENT IN THE HEARING HERE AND HOW IN A GENERAL SENSE THAT IN A GENERAL THEORY THESE INCIDENTS -- STRIKE THAT. IN A GENERAL SENSE, IN A GENERAL THEORY, HOW DIFFERENT TYPES OF BATTERING MIGHT BE CONNECTED TOGETHER WITHIN A DESIGN; NOT AS TO THE SPECIFICS OF THE CASE HERE.

70 THE COURT:

ALL RIGHT.

71 MR. GORDON:

GOING TO THAT LIMITED PURPOSE.

72 THE COURT:

ALL RIGHT. MR. BAILEY, I'M GOING TO SUSTAIN THE OBJECTION AT THIS POINT.

73 MR. BAILEY:

ALL RIGHT.

74 Q:

IS IT PART OF YOUR SCIENCE, DOCTOR, TO TRY TO IDENTIFY CHARACTERISTICS OF BOTH VICTIMS AND BATTERERS?

75 A:

YES, IT IS.

76 Q:

IN SUCH CASES?

77 A:

YES.

78 Q:

SO THAT YOU FORMULATE EVENTUALLY, DO YOU NOT, SORT OF A CHECKLIST?

79 A:

THAT'S RIGHT.

80 Q:

ARE YOU FAMILIAR WITH DR. LENORE WALKER?

81 A:

YES, I AM.

82 Q:

DO YOU KNOW HER?

83 A:

YES, I DO.

84 Q:

ARE YOU FAMILIAR WITH HER WRITINGS?

85 A:

YES, I AM.

86 Q:

ARE YOU FAMILIAR WITH HER CHECKLIST?

87 A:

YES, I AM.

88 Q:

ALL RIGHT. DO YOU AGREE WITH THEM?

89 (NO AUDIBLE RESPONSE.)
90 Q:

IN YOUR OWN PRACTICE?

91 A:

GENERALLY, YEAH. YEAH.

92 Q:

OKAY. THERE ARE CERTAIN THINGS YOU WOULD EXPECT TO FIND IN A PERSON THAT HAS BEEN BATTERED, CORRECT?

93 A:

UH-HUH.

94 Q:

AS SET FORTH IN HER BOOK THE BATTERED WOMAN, WHICH IS VERY WELL-KNOWN IN YOUR PROFESSION, IS IT NOT?

95 A:

YES, IT IS.

96 Q:

AND SHE HAS DETAILED WHAT YOU SHOULD LOOK FOR, BOTH AS TO THE VICTIM AND THE BATTERER, THAT IS, CHARACTERISTICS -- I BELIEVE COMMON CHARACTERISTICS OF BATTERED WOMEN, SHE LISTS NINE. ARE YOU FAMILIAR WITH THEM?

97 A:

RIGHT. WELL, MY MEMORY COULD USE A LITTLE BIT OF REFRESHING ACTUALLY IN TERMS OF THOSE NINE CHARACTERISTICS.

98 Q:

WOULD YOU LIKE A COPY OF THE BOOK?

99 A:

YES.

100 MR. BAILEY:

OKAY.

101 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)
102 MR. BAILEY:

MAY I APPROACH THE WITNESS, YOUR HONOR?

103 THE COURT:

YOU MAY.

104 DR. DONALD DUTTON:

THANK YOU. UH-HUH.

105 Q:

BY MR. BAILEY: WHAT IS THE FIRST CHARACTERISTIC?

106 A:

HAS LOW SELF-ESTEEM.

107 Q:

DO YOU HAVE ANY INFORMATION OR EVIDENCE BEFORE YOU AS TO WHETHER OR NOT THE VICTIM IN THIS CASE HAD LOW SELF-ESTEEM?

108 A:

I HAVE NO INFORMATION.

109 MR. GORDON:

YOUR HONOR, OBJECTION. WE ARE GOING INTO THE SAME MATTER OF INQUIRY, UNLESS YOU WANT TO OPEN IT UP TO ALL THIS, BUT WE ARE GOING INTO EXACTLY THE SAME LINE OF INQUIRY.

110 MR. BAILEY:

MAY IT PLEASE THE COURT, COUNSEL FOR THE PEOPLE JUST DETAILED THINGS THAT ARE LOOKED FOR, SCALES THAT ARE USED, MULTIPLICATIONS THAT ARE USED TO TRY AND IDENTIFY BATTERERS. I THINK I AM ENTITLED TO GO INTO THAT SUBJECT AS FAR AS HE'S THE ONE THAT PUT THE POWER WHEEL IN HIS BRIEF.

111 MR. GORDON:

AS TO DIAGNOSING A PERSON, UNLESS WE WANT TO GET INTO TESTIMONY ON BOTH SIDES AS TO PROFILING THIS PARTICULAR DEFENDANT AND THIS VICTIM. THAT IS A VERY DIFFERENT SET OF FACTS THAN SAYING ARE THERE CERTAIN -- THESE ARE NINE CHARACTERISTICS OF A BATTERED WOMAN. WOULD YOU AGREE THAT THESE ARE NINE CHARACTERISTICS OF A BATTERED WOMAN IN ANY GENERAL POPULATION OF BATTERED WOMEN? I DON'T HAVE ANY OBJECTION TO THAT QUESTION WHATSOEVER. TO NOW TAKE ANOTHER STEP AND SAY LET'S LOOK AT THIS CASE WOULD BE LIKE FOR ME TO SAY DO YOU HAVE AN OPINION ABOUT MR. SIMPSON RIGHT NOW, WHICH I DIDN'T DO. THAT IS TWO VERY, VERY DIFFERENT THINGS, AND THE SECOND ONE ISN'T GOING TO BE OFFERED HERE.

112 MR. BAILEY:

IF IT PLEASE THE COURT, I HAVE ALREADY DEVELOPED HE COULD NOT ETHICALLY GIVE AN OPINION ABOUT MR. SIMPSON BECAUSE HE HAS NEVER EXAMINED HIM, AND I DON'T INTEND TO ASK THAT QUESTION. I'M ASKING ABOUT A SCIENCE OF STUDYING AND DEFINING BATTERED WOMEN AND BATTERERS WHICH THE PROSECUTION HAS MADE RELEVANT.

113 THE COURT:

ALL RIGHT. LET'S LEAVE IT AT THAT.

114 MR. BAILEY:

ALL RIGHT.

115 Q:

WOULD YOU SIMPLY READ THEN THE BALANCE OF THE CHARACTERISTICS THAT ARE DEFINED.

116 A:

OKAY. DR. WALKER'S LIST IS THAT BATTERED WOMEN HAVE LOW SELF-ESTEEM, THAT THEY BELIEVE ALL THE MYTHS ABOUT BATTERING RELATIONSHIPS, THAT THEY ARE TRADITIONALISTS ABOUT THE HOME, THEY STRONGLY BELIEVE IN FAMILY UNITY AND PRESCRIBED FEMININE SEX-ROLE STEREOTYPE, THEY ACCEPT RESPONSIBILITY FOR THE BATTERER'S ACTIONS, THEY SUFFER FROM GUILT, YET DENY THE TERROR AND ANGER THAT THEY FEEL, THAT THEY PRESENT A PASSIVE FACE TO THE WORLD BUT HAVE THE STRENGTH TO MANIPULATE THEIR ENVIRONMENT ENOUGH TO PREVENT FURTHER VIOLENCE AND BEING KILLED, THAT THEY HAVE SEVERE STRESS REACTIONS WITH PSYCHOPHYSIOLOGICAL COMPLAINTS, AND THAT THEY USE SEX AS A WAY TO ESTABLISH INTIMACY, AND THEY BELIEVE THAT NO ONE WILL BE ABLE TO RESOLVE THEIR PREDICAMENT EXCEPT THEMSELVES.

117 Q:

NOW, TURNING OVER TO PAGE 36, DO WE HAVE A SIMILAR LIST DEFINING WHAT WE MIGHT EXPECT TO FIND IN A BATTERER?

118 A:

UH-HUH.

119 Q:

ALL RIGHT. AND WHAT ARE THOSE?

120 A:

WE HAVE A LOW SELF-ESTEEM, BELIEVES ALL THE MYTHS ABOUT BATTERING RELATIONSHIPS, IS A TRADITIONALIST BELIEVES IN MALE SUPREMACY AND THE STEREOTYPED MASCULINE SEX ROLE IN THE FAMILY, BLAMES OTHERS FOR HIS ACTIONS, HIS PATHOLOGICALLY JEALOUS, PRESENTS A DUAL PERSONALITY, HAS SEVERE STRESS REACTIONS, DURING WHICH HE USES DRINKING AND WIFE BATTERING TO COPE, FREQUENTLY USES SEX AS AN ACT OF AGGRESSION TO ENHANCE SELF-ESTEEM IN VIEW OF WANING VIRILITY, MAY BE BISEXUAL, DOES NOT BELIEVE HIS VIOLENT BEHAVIOR SHOULD HAVE NEGATIVE CONSEQUENCES.

121 Q:

ALL RIGHT. NOW, DO I CORRECTLY UNDERSTAND THAT AS TO NEITHER THE VICTIM IN THIS CASE NOR THE DEFENDANT HAVE YOU ATTEMPTED TO MAKE ANY ANALYSIS OF THESE CHARACTERISTICS?

122 A:

THAT'S CORRECT.

123 Q:

HAVE YOU MADE ANY REFERENCE IN THE TESTIMONY GIVEN TODAY TO THE SO-CALLED POWER AND CONTROL WHEEL WHICH APPEARS IN THE BRIEF OF THE PEOPLE?

124 A:

NO, I HAVE NOT.

125 Q:

I BELIEVE YOU SAID YOU DO USE THAT, HOWEVER, AND RECOGNIZE IT?

126 A:

I DO -- YEAH, WE USE IT IN OUR TREATMENT GROUPS, THAT'S TRUE.

127 Q:

ALL RIGHT.

128 A:

YEAH.

129 Q:

NOW, IS IT FAIR TO SAY THAT NO SPECIMEN IS LIKELY TO HIT EVERY POINT ON THE CHECKLIST?

130 A:

YES, THAT'S FAIR.

131 Q:

AND THAT SOMEBODY THAT HIT NONE OF THE POINTS ON THE CHECKLIST WOULD PROBABLY BE EXCLUDED AS A CANDIDATE?

132 A:

I WOULD AGREE WITH THAT.

133 Q:

WHAT PERCENTAGE OF POINTS DO YOU LOOK FOR BEFORE YOU THINK YOU MAY HAVE A CANDIDATE THAT NEEDS FURTHER EXAMINATION?

134 A:

WELL, ARE YOU TALKING ABOUT DR. WALKER'S CHECKLIST OR THESE SCALES THAT --

135 Q:

THE DULUTH, MINNESOTA, POWER AND CONTROL WHEEL BLOWN UP OVER HERE A GREAT BIG PICTURE?

136 A:

WE DO NOT USE THAT SCALE OR DIAGNOSTIC PURPOSES. WE USE IT FOR DIDACTIC PURPOSES WITHIN A TREATMENT PURPOSE. FOR DIAGNOSTIC PURPOSES WE USE A VARIETY OF PSYCHOLOGICAL TESTS WHICH HAVE NOT BEEN PRESENTED HERE TODAY AND THAT I HAVE NOT DESCRIBED.

137 Q:

ALL RIGHT. NOW, IN ORDER TO PROPERLY ANSWER QUESTIONS ABOUT THE EXISTENCE OF ANY BATTERING IN THIS CASE --

138 A:

YES.

139 Q:

-- SINCE THE VICTIM S NO LONGER WITH US --

140 A:

YES.

141 Q:

-- YOU WOULD HAVE TO FOCUS YOUR ATTENTION, FOR AN EXAMINATION PURPOSES, ON THE DEFENDANT, CORRECT?

142 MR. GORDON:

OBJECTION, IT IS IRRELEVANT AND BEYOND THE SCOPE.

143 THE COURT:

OVERRULED. YOU CAN ANSWER THE QUESTION.

144 DR. DONALD DUTTON:

WELL, I THINK UNDER THE CIRCUMSTANCE THAT THE PSYCHOLOGICAL TESTS THAT WE HAVE USED TO DETERMINE WHETHER A MAN HAS WHAT WE CALL PROPENSITY FOR ABUSIVENESS OR NOT WERE NOT DESIGNED TO BE USED WITH A PERSON IN MR. SIMPSON'S CIRCUMSTANCES.

145 Q:

BY MR. BAILEY: OKAY. SO YOU ARE SAYING THEN THAT TO EXAMINE HIM --

146 A:

WOULD NOT BE FAIR. IT WOULD NOT BE FAIR USING THESE TESTS.

147 Q:

OKAY. SO IF THIS WERE YOUR CASE, SO TO SPEAK, AND WE HAD ASKED YOU TO EXAMINE MR. SIMPSON TO GIVE US AN OPINION, THERE ARE NO PSYCHOLOGICAL TESTS THAT YOU WOULD HAVE CAUSED TO BE ADMINISTERED TO LEARN ABOUT HIS PERSONAL TRAITS?

148 A:

I WOULDN'T USE THE ONES THAT WE TRADITIONALLY USED IN OUR RESEARCH TO DIAGNOSE A PROPENSITY FOR ABUSIVENESS WITH A MAN WHO WAS INCARCERATED UNDER THE CONDITIONS THAT MR. SIMPSON IS FACING. I WOULDN'T HAVE FELT THAT WAS FAIR TO HIM AND I WOULDN'T HAVE USED THEM UNDER THOSE CIRCUMSTANCES.

149 Q:

IS IT BECAUSE OF HIS PRESENT CONFINEMENT THAT YOU WOULDN'T USE THEM OR BECAUSE OF THE CHARGES PENDING OR FOR SOME OTHER REASON?

150 A:

A COMBINATION REALLY.

151 Q:

ALL RIGHT.

152 A:

YEAH.

153 Q:

WOULD YOU HAVE EXAMINED HIM PERSONALLY?

154 A:

I WOULD HAVE EXAMINED HIM PERSONALLY, YEAH.

155 Q:

ALL RIGHT. NOW, RELATING ONCE AGAIN TO YOUR EXPERIENCE, AS I UNDERSTAND IT, THE BULK OF IT IS WITH PEOPLE WHO ARE DEFINED AS BATTERERS, EITHER BY THEMSELVES OR BY A COURT?

156 A:

THAT'S CORRECT.

157 Q:

SO THAT WHEN THEY COME TO YOU, YOU KNOW WHAT THEY ARE? YOU ARE NOT ANSWERING THE QUESTION IS THIS PERSON BATTERED?

158 A:

WELL, OKAY. LET ME JUST SORT OF QUALIFY THAT SOMEWHAT. WE HAVE OF COURSE GONE OUT AND COLLECTED CONTROL GROUP DATA FOR OUR TESTS SO WE HAVE ADVERTISED IN NEWSPAPERS. WE'VE GOT BLUE COLLAR MEN, WE HAVE GOT MEN FROM EVERY WALK OF LIFE, BECAUSE WE DON'T WANT TO GIVE THE SCALE OUT TO MEN WHO ARE SELF-DEFINED BATTERERS, SO WE HAVE SAMPLED ACROSS THE BOARD TO CORROBORATE THE SCALES.

159 Q:

OKAY BUT IN HOW MANY CASES IS SOMEONE SENT TO YOU AND YOU HAVE DISCHARGED THEM AS NOT BEING A BATTERER? IN OTHER WORDS, A MISTAKE?

160 A:

FOR RESEARCH PURPOSES OR TREATMENT PURPOSES?

161 Q:

TREATMENT.

162 A:

UMM, I WOULD SAY 15 PERCENT OF THE CASES WE RECEIVE MAYBE.

163 Q:

DO NOT NEED WHATEVER IT IS YOU OFFER, IN YOUR JUDGMENT, AND AWAY THEY GO?

164 A:

YEAH, YEAH.

165 Q:

HAVE YOU DONE STUDIES OR READ ABOUT STUDIES WHERE THERE WAS AN ATTEMPT TO PREDICT, FROM INFORMATION GAINED ABOUT A BATTERER, AS TO WHAT FUTURE CONDUCT THERE MIGHT BE?

166 A:

YES. IN FACT, WE HAVE DONE ONE.

167 Q:

UH-HUH.

168 A:

UH-HUH.

169 Q:

AND WHAT KIND OF ACCURACY HAVE YOU BEEN ABLE TO DEMONSTRATE?

170 A:

WELL, THIS IS -- I HOPE YOU DON'T MIND MY USING THE TERM POSTDICTION STUDY.

171 Q:

POST WHAT?

172 A:

POSTDICTION STUDY, A RETROSPECTIVE PREDICTION STUDY. IN OTHER WORDS, WHAT I MEAN IS THAT WE GO OUT AND COLLECT ALL THE DATA ON THE MEN THAT WE THINK ARE ABUSIVE. SOME OF THEM ARE IN TREATMENT GROUPS AND SOME OF THEM ARE MEN THAT HAVE ANSWERED NEWSPAPER ADS. WE DO THE PSYCHOLOGICAL PROFILES ON THESE MEN AND THEY WE TRY TO PREDICT WHETHER THEIR WIVES ARE GOING TO TRY TO CLASSIFY THESE MEN AS ABUSIVE OR NOT. OUR ACCURACY RATE IS AROUND 88 PERCENT.

173 Q:

THAT WAS NOT THE THRUST OF MY QUESTION, BUT PERHAPS I DIDN'T WORD IT TOO ARTFULLY?

174 A:

OKAY.

175 Q:

THESE ARE THE VICISSITUDES OF GIVE AND TAKE.

176 A:

OKAY.

177 Q:

WHAT I WANT TO KNOW IS, IS IT PART OF YOUR RESPONSIBILITY, WHEN YOU TREAT SOMEONE WHO HAS ALLEGEDLY MADE SOME KIND OF THREAT OR ENGAGED IN SOME KIND OF VIOLENCE, TO PREDICT WHETHER IT WILL ESCALATE TO ITS ULTIMATE FORM?

178 A:

UMM, OKAY, I UNDERSTAND YOU. YES.

179 Q:

OKAY.

180 A:

YES, IT IS.

181 Q:

NOW, WHAT DO THOSE STUDIES SHOW ABOUT YOUR ABILITY TO EXAMINE SOMEONE AND PROJECT WHETHER THEY WILL OR WILL NOT ENGAGE IN SERIOUS --

182 A:

I DON'T HAVE EMPIRICAL DATA ON THAT I'M AFRAID.

183 Q:

THAT REALLY HASN'T BEEN DONE?

184 A:

NO.

185 Q:

OKAY. SUPPOSING IN THE COURSE OF RUNNING YOUR CHECKLISTS, YOUR OWN OR DR. WALKER'S OR WHICHEVER ONES YOU USE --

186 A:

RIGHT.

187 Q:

-- YOU FIND PEOPLE WHO ARE RADICALLY THE OPPOSITE OF THE TYPICAL BATTERER.

188 A:

RIGHT.

189 Q:

IN SOME CATEGORY.

190 A:

RIGHT.

191 Q:

AS AN EXAMPLE --

192 A:

UH-HUH.

193 Q:

-- I THINK YOU HAVE SAID IN THE -- AND THE LITERATURE SAYS THAT BATTERERS LIKE TO CONTROL ECONOMICALLY THEIR VICTIMS TO A DEGREE --

194 A:

UH-HUH.

195 Q:

-- SO THAT THEY CAN REWARD AND PUNISH, GIVE AND TAKE AND KEEP THEM UNDER THEIR THUMB?

196 A:

UH-HUH.

197 Q:

NOW, IF YOU FIND SOMEONE WHO DOES JUST THE OPPOSITE --

198 A:

UH-HUH.

199 Q:

-- GENEROUS, GIVING, PASSES TITLE ON POSSESSIONS, GIVES BEFORE BEING ASKED, ET CETERA, DOES THAT FLY IN THE FACE OF BATTERER'S SYNDROME OR CAN IT BE AN EXCEPTION?

200 A:

WELL, IT IS AN INTERESTING QUESTION. WHAT -- I HAVE TO KNOW A LITTLE BIT MORE ABOUT THAT PERSON AND I WOULD HAVE TO KNOW A LITTLE BIT MORE ABOUT THE MOTIVATION IN GIVING, BECAUSE I'M SURE YOU ARE AWARE, THE MOTIVES FOR GIVING ARE NOT ALWAYS WHAT THEY APPEAR TO BE. SOMETIMES THERE CAN BE A CONTROL MOTIVE BEHIND THE GIVING OF MONEY AS WELL, SO IT IS HARD TO ANSWER THAT QUESTION IN THE ABSTRACT.

201 Q:

ALL RIGHT. WELL, SIMPLY PUT, IF I LOAN YOU MONEY, I HAVE SOME CONTROL OVER YOU, CORRECT?

202 A:

THAT'S RIGHT, OR EVEN IF YOU GAVE ME MONEY YOU MIGHT HAVE SOME CONTROL OVER ME BECAUSE I WOULD OWE YOU SOMETHING. I WOULD FEEL INDEBTED TO YOU.

203 Q:

A MORAL OBLIGATION?

204 A:

THAT'S RIGHT.

205 Q:

SUPPOSING I REPEATEDLY GIVE YOU MONEY AND YOU DON'T GIVE ME ANY MONEY BACK?

206 A:

UH-HUH.

207 Q:

I KNOW THAT IS A DELECTABLE THING TO CONTEMPLATE, BUT JUST TAKE IT HYPOTHETICALLY.

208 A:

I GUESS I WOULD HAVE TO KNOW MORE ABOUT THE REASONS WHY YOU ARE GIVING ME MONEY. I MEAN, IT IS REALLY HARD TO COMMENT ON AN ABSTRACT CASE.

209 Q:

SUPPOSING YOU ARE A WOMAN AND I LOVE YOU?

210 A:

PARDON ME?

211 Q:

SUPPOSING YOU ARE A WOMAN AND I LOVE YOU?

212 A:

OKAY. I'M A WOMAN AND YOU LOVE ME AND YOU ARE GIVING ME THIS MONEY OVER AND OVER AND OVER.

213 Q:

I'M GIVING YOU A CONDOMINIUM, A PORSCHE, A MERCEDES AND A FERRARI, ALL IN YOUR NAME. IS THAT ECONOMIC CONTROL?

KEY QUOTE
214 A:

ARE YOU -- I GUESS MY QUESTION IS IS THERE ARE ANY STRINGS ATTACHED?

215 Q:

NO.

216 A:

NO STRINGS ATTACHED?

217 Q:

NO. WE AREN'T EVEN MARRIED.

218 A:

I CAN DO WHATEVER I WANT TO DO.

219 Q:

WE ARE NOT EVEN MARRIED. YOU CAN TAKE OFF.

220 A:

IF THERE WERE ABSOLUTELY NO STRINGS ATTACHED, THEN I WOULD AGREE WITH YOU, THAT THAT WOULD SEEM TO BE MAGNANIMOUS TO THE NTH DEGREE AND NOT A TYPE OF CONTROL.

KEY QUOTE
221 Q:

ALL RIGHT. OKAY.

222 A:

YES.

223 Q:

NOW, YOU HAVE, I BELIEVE, SAID THAT TERMINATION OF A RELATIONSHIP WHETHER BY DIVORCE OR REJECTION OR ANYTHING ELSE, IT IS AN IMPORTANT ELEMENT USUALLY FOR BATTERERS THAT MAY TRIGGER THEIR CONDUCT?

224 A:

YES, IT MAY.

225 Q:

AND THAT JEALOUSY AND OFTEN VIOLENCE RESULTING IN JEALOUSY RESULTING IN TURN FROM THE INSECURITY OF A PERSONAL IS OFTEN TYPICAL AND AGAIN A TRIGGER OF SOME VIOLENCE?

226 A:

UH-HUH.

227 Q:

HOW MANY OF THE BATTERERS THAT YOU EXAMINED HAD COME UPON THEIR EX-WIVES PERFORMING A SEX ACT AND DONE NOTHING ABOUT IT?

228 A:

DON'T HAVE THOSE NUMBERS.

229 Q:

NEVER HAPPENED IN YOUR EXPERIENCE, DID IT?

230 A:

OH, I WOULDN'T -- NO, I WOULDN'T SAY IT NEVER HAPPENED. I JUST WOULD SAY, NO, I CAN RECALL IT BEING RECOUNTED TO ME IN TREATMENT GROUPS, OKAY, BUT WE NEVER COUNTED THEM UP. WE NEVER MADE A SYSTEMATIC STUDY.

231 Q:

BUT IS THAT TYPICAL CONDUCT FOR A PERSON WHO IS JEALOUS?

232 A:

WELL, AGAIN, I GUESS IT REALLY DEPENDS ON HOW THE SITUATION IS BEING HANDLED. I MEAN, IF I JUST SIMPLY WALKED AWAY FROM IT AND WAS UNFAZED BY IT, NO, IT WOULD BE ATYPICAL.

233 Q:

BUT YOU DON'T DO THAT IN THIS CASE. YOU COME BACK THE NEXT DAY AND VERY CORDIALLY GREET THE BENEFICIARY OF THE FELLATIO.

234 A:

UH-HUH.

235 Q:

THAT IS A PRETTY GOOD SHOW OF EQUANIMITY, ISN'T IT?

236 A:

TOWARD THE MAN.

237 Q:

AND THE SAME WITH THE WOMAN, NO ANGER, NO CRITICISM, EXCEPT FOR THE WELFARE OF THE CHILDREN. YOU READ THAT, DID YOU?

238 MR. GORDON:

ASSUMES A FACT NOT IN EVIDENCE AND MISSTATES THE EVIDENCE.

239 THE COURT:

MR. BAILEY, I THINK WE ARE DRIFTING BACK OVER.

240 MR. BAILEY:

VERY WELL.

241 THE COURT:

IN FACT, WE ARE MORE THAN DRIFTING. WE ARE RIGHT IN THE MIDDLE OF IT.

242 MR. BAILEY:

YOUR HONOR, I WILL MAKE FOR THE FLANK QUICKLY.

243 THE COURT:

PLEASE.

244 Q:

BY MR. BAILEY: IF ONE WERE TO HYPOTHETICALLY LEARN FROM A CLOSE FRIEND THAT HE HAD BEEN HAVING RELATIONS WITH AN EX-WIFE AND NOT REACT, THAT WOULD BE SOMEWHAT ATYPICAL FOR A BATTERER, WOULD IT NOT?

245 A:

LEARNED FROM A CLOSE FRIEND THAT HIS WIFE WAS HAVING A RELATIONSHIP?

246 Q:

YOU AND I ARE BUDDIES. I AM GETTING DIVORCED. I AM DIVORCED. AND YOU AND I HAVE A COUPLE ONE NIGHT AND SAY, YOU KNOW, I WAS WITH GRETA LAST NIGHT AND SHE WAS GREAT.

247 A:

RIGHT.

248 Q:

AND I SAID OKAY. SHE IS FREE. YOU KNOW, SHE IS DIVORCED. NO REACTION. ISN'T THAT ATYPICAL?

249 MR. GORDON:

THAT ASSUMES A FACT NOT IN EVIDENCE IN THIS CASE.

250 MR. BAILEY:

I'M ASKING A HYPOTHETICAL.

251 THE COURT:

OVERRULED.

252 DR. DONALD DUTTON:

HYPOTHETICAL QUESTION?

253 Q:

BY MR. BAILEY: YES.

254 A:

IT I WOULD ATYPICAL.

255 MR. COCHRAN:

I COULDN'T HEAR THAT ANSWER.

256 DR. DONALD DUTTON:

IT WOULD BE ATYPICAL.

257 Q:

BY MR. BAILEY: UNUSUAL, NOT CONSISTENT?

258 A:

YES.

259 Q:

YOU HAVE I THINK FOCUSED YOUR MAIN CONCERN IN BATTERERS ON THE NEED TO CONTROL ECONOMICALLY AND IN OTHER WAYS, RIGHT?

260 A:

UH-HUH.

261 Q:

WHEN ONE SHOWS NO INTEREST IN THE CONDUCT OF THE ALLEGED OBJECT OF THE BATTERING, IS THAT NOT INCONSISTENT WITH THE SYNDROME?

262 A:

IF THE BATTERER SHOWS NO INTEREST IN THE WOMAN?

263 Q:

RIGHT.

264 A:

THAT WOULD BE INCONSISTENT.

265 Q:

HAS REASON TO BELIEVE SHE IS COMING IN AT 3:00, 4:00 OR 5:00 IN THE MORNING, BUT DOESN'T DO OR SAY ANYTHING ABOUT IT, THAT IS INCONSISTENT, ISN'T IT, WITH THIS FIERCE JEALOUSY THAT IS PART OF WHAT YOUR STUDY?

266 A:

UH-HUH.

267 THE COURT:

EXCUSE ME, DOCTOR. WHEN YOU SAY "UH-HUH" DO YOU MEAN YES OR NO?

268 DR. DONALD DUTTON:

YES.

269 Q:

BY MR. BAILEY: IF WE CAN SURMOUNT THE BATTERY OF OUR COMMON LANGUAGE.

270 A:

YES.

271 Q:

DOES IT MAKE ANY DIFFERENCE, WHEN YOU EVALUATE ONE OF THESE CASES, AS TO WHAT THE HISTORY OF THE SUBJECT IS?

272 A:

YES, IT DOES.

273 Q:

OKAY.

274 A:

YOU MEAN THE MAN'S PERSONAL HISTORY OR THE VICTIM'S HISTORY, THE HISTORY OF THE RELATIONSHIP?

275 Q:

YES.

276 A:

THEY ALL ARE IMPORTANT.

277 Q:

IF ONE WERE IN THE BUSINESS WHERE OTHERS WERE CONTINUALLY TRYING TO BEAT, HURT AND BREAK HIM AND ONE DIDN'T REACT IN ANGER, WOULDN'T THAT BE INCONSISTENT WITH THE KIND OF FRAIL PERSONALITY THAT WE FIND IN BATTERERS?

278 A:

NOT NECESSARILY, BECAUSE ONE OF THE THINGS I THINK THAT IS TRUE, AND DR. WALKER MENTIONS THIS ALSO IN HER CHECKLIST, THAT IS, THERE DOES SEEM TO BE ALMOST A KIND OF DUAL PERSONALITY WHERE THE RAGE IS DIRECTED PRIMARILY TOWARDS AN INTIMATE WOMAN, SO THESE MEN DON'T ALWAYS DEMONSTRATE ANGER AGAINST OTHER MEN, EVEN MEN WHO ARE ENGAGED IN PHYSICAL PURSUITS WITH THEM.

279 Q:

BEATING UP ON THEM?

280 A:

YEAH. THAT'S RIGHT. THAT WOULD NOT -- BECAUSE A MAN IS PHYSICALLY ABUSIVE AT HOME DOES NOT NECESSARILY MEAN THAT HE WOULD SHOW AN ANGER RESPONSE IN HIS INTERACTION WITH OTHER MEN.

281 Q:

EVEN THOUGH THEY WERE PHYSICALLY TRYING TO HURT HIM AND HE KNEW IT?

282 A:

I MEAN IF HE HAS TO DEFEND HIMSELF, YES.

283 Q:

I'M NOT TALKING ABOUT DEFEND HIMSELF.

284 A:

OKAY.

285 Q:

YOU ARE COMING FROM A COUNTRY FAMOUS FOR RATHER A ROUGH SPORT CALLED ICE HOCKEY?

286 A:

THAT'S RIGHT.

287 Q:

WHICH CAN BE VERY ASSAULTIVE?

288 A:

THAT'S RIGHT.

289 Q:

AND IS CHARACTERIZED BY THE OUTBREAK OF LOSSES OF TEMPER BY THE PLAYERS WHO FIGHT, TRUE?

290 A:

UH-HUH.

291 Q:

EVEN THOUGH IT IS AGAINST THE RULES TO FIGHT, THEY DO IT?

292 A:

IT IS DEBATEABLE. THERE SEEMS TO BE A KIND OF PERMISSION TO DO CERTAIN THINGS AND NOT DO CERTAIN OTHER THINGS. IF YOU KICK ANOTHER PLAYER WITH A SKATE, FOR EXAMPLE, THAT IS A NO-NO, BUT IF YOU GET INTO A FIST FIGHT WITH SOMEONE YOUR SIZE AT THE BLUE LINE, THEN THE REFEREES LET THAT GO BECAUSE IT IS GOOD FOR THE GATE, SO --

293 Q:

IT IS GOOD FOR THE GATE?

294 A:

IT IS KIND OF AGAINST THE RULES AND IT IS KIND OF NOT AGAINST THE RULES.

295 Q:

IF YOU WHACK HIM HARD ENOUGH YOU CAN GET TRIED FOR MANSLAUGHTER?

296 A:

YES.

297 Q:

DO YOU KNOW WHAT THE LADY BING TROPHY IS, DOCTOR?

298 A:

YES, I DO.

299 Q:

IS THAT NOT AWARDED TO THE PLAYER IN THE NATIONAL HOCKEY LEAGUE WHO SHOWS THE LEAST PROPENSITY --

300 A:

GREATEST SKILLS WITH THE LEAST PROPENSITY FOR VIOLENCE.

301 Q:

NOT MANY PENALTY MINUTES?

302 A:

THAT'S RIGHT.

303 Q:

DO YOU KNOW THE CAPTAIN OF A FOOTBALL TEAM, HOW HE GETS APPOINTED, HOW HE GETS SELECTED?

304 A:

NOT EXACTLY.

305 Q:

WELL, HYPOTHETICALLY ASSUME --

306 A:

YEAH.

307 Q:

-- THAT HE IS SELECTED BECAUSE OF HIS GENERAL EQUANIMITY IN THE FACE OF CONTINUOUS ASSAULTS AND HIS GOOD SPORTSMANSHIP AND FAIRNESS AS WELL AS HIS ABILITY.

308 A:

UH-HUH.

309 Q:

WOULD THAT BE CONSISTENT WITH THE KIND OF PERSON YOU FIND SITTING AT YOUR TABLE?

310 A:

NOT NECESSARILY.

311 Q:

IN OTHER WORDS, WOULD YOU BE SURPRISED TO FIND THE WINNER OF THE LADY BING TROPHY BEING AN ASSAULTIVE PERSON?

312 A:

UMM, THE LAST BOOK I WROTE ON THIS, THE PRINCIPLE DANCER OF THE NEW YORK CITY BALLET HAD JUST BEEN ARRESTED FOR WIFE ASSAULT. I WOULD NOT BE SURPRISED.

313 Q:

OKAY. THAT IS TYPICAL OR WAS IT SO EXTRAORDINARY YOU PUT IT IN YOUR BOOK?

314 A:

NO, I JUST PUT IT IN THE BOOK TO SHOW THE FACT THAT THERE REALLY ARE TWO PERSONALITIES AT WORK HERE AND YOU SIMPLY CAN'T DRAW CONCLUSIONS ABOUT THE INTIMATE PERSONALITY FROM WHAT GOES ON IN TRANSACTIONS OUTSIDE THE HOME.

315 Q:

ALL RIGHT. BUT THAT IS IN CASES WHERE YOU FIND IN FACT A DUAL PERSONALITY, CORRECT?

316 A:

RIGHT, BUT EVEN DR. WALKER IN HER LIST MENTIONED THIS KIND OF DUAL PERSONALITY AS BEING TYPICAL OF BATTERERS.

317 Q:

YES?

318 A:

YES.

319 Q:

CAN BE?

320 A:

YES.

321 Q:

BUT IF THE DUAL PERSONALITY ISN'T THERE, THEN THE PEACEFUL CONDUCT IS CONTRAINDICATED IN A BATTERER, IS IT NOT?

322 A:

RIGHT.

323 Q:

IF YOU CAN'T TURN IT ON AND OFF?

324 A:

WELL, YES, BUT I THINK THE POINT I'M TRYING TO MAKE IS THAT IT IS FREQUENTLY THE CASE THAT THE DUAL PERSONALITY IS THERE AND TO DRAW CONCLUSIONS OR INFERENCES ABOUT WHAT THE MAN IS LIKE IN TERMS OF HIS RELATIONSHIP WITH HIS WIFE ON THE BASIS OF HOW HE IS AND HIS INTERACTIONS WITH MEN IN THE PUBLIC WORLD IS ERRONEOUS AND THAT IS SORT OF ONE OF THE MYTHS THAT THE RESEARCH IN THIS AREA IS TRYING TO DISPEL.

THE TWO PERSONALITIES ARE -- YOU SIMPLY DIDN'T PREDICT ONE FROM THE OTHER.

325 Q:

WHAT YOU ARE SAYING IS THAT IN SOME PEOPLE THOSE TWO OPPOSITES CAN LIVE TOGETHER, IN NORMAL PEOPLE THEY DON'T LIVE TOGETHER, PEOPLE WITH ONE PERSONALITY?

326 A:

YES, THAT'S CORRECT.

327 Q:

OKAY. NOW, HAS IT EVER BEEN PART OF YOUR BUSINESS TO DEAL NOT WITH BATTERERS AS SUCH, BUT WITH PEOPLE WHO HAVE COMMITTED HOMICIDE?

328 A:

I HAVE ON OCCASION DEALT WITH PEOPLE WHO COMMITTED HOMICIDE, YES.

329 Q:

ARE YOU AWARE OF ANY OF THE CHECKLISTS THAT HAVE BEEN DEVELOPED AS TO WHAT TO LOOK FOR IN PEOPLE WHO HAVE RECENTLY COMMITTED A HOMICIDE?

330 A:

YES, I AM.

331 MR. GORDON:

OBJECT AS TO VAGUE AS TO WHAT TYPE OF HOMICIDE AND THEREFORE RELEVANCE OBJECTION.

332 THE COURT:

OVERRULED.

333 DR. DONALD DUTTON:

I'M FAMILIAR WITH DR. DEITZ' CHECKLIST, FOR EXAMPLE, YES.

334 Q:

BY MR. BAILEY; IN YOUR FIELD MOST OF THE HOMICIDES THAT YOU WOULD COME IN CONTACT WITH WOULD BE RELATIONSHIP HOMICIDES, WOULD THEY NOT, AS OPPOSED TO PAID ASSASSINATIONS?

335 A:

THAT'S RIGHT.

336 Q:

VEHICULAR?

337 A:

THAT'S RIGHT.

338 Q:

ET CETERA?

339 A:

THAT'S RIGHT.

340 Q:

OKAY. PEOPLE WHO LOST THEIR TEMPER OR WORSE?

341 A:

THAT'S RIGHT.

342 Q:

AND IS IT FAIR TO SAY THAT THERE ARE SOME DEFINITIONS OF PERSONALITY TRAITS, NOT PERSONALITY, BUT TRAITS OR ACTIONS OR CONDUCT, THAT ARE LOOKED FOR --

343 A:

YES.

344 Q:

-- WHEN HOMICIDE HAS BEEN PERPETRATED AND IT IS KNOWN THAT THIS PERSON IS THE PERPETRATOR?

345 A:

YES.

346 Q:

CAN YOU TELL US JUST OFFHAND HOW MANY PEOPLE YOU HAVE EXAMINED THAT HAVE RECENTLY COMMITTED A HOMICIDE, SAY, 48, 72 HOURS, SOMETHING LIKE THAT, IN A WEEK?

347 A:

IN THE LAST 48 OR 72 HOURS?

348 Q:

OR LAST WEEK WHILE THE SYMPTOMS ARE STILL PRESENT?

349 A:

I HAVE --

350 MR. GORDON:

OBJECT TO THAT. THAT ASSUMES A FACT NOT IN EVIDENCE.

351 Q:

BY MR. BAILEY: HYPOTHETICALLY?

352 MR. GORDON:

WITH REGARDS TO SOME TYPE OF SYMPTOMS BEING PRESENT? ALSO RELEVANCE OBJECTION TO THIS TYPE OF QUESTION.

353 THE COURT:

OVERRULED. YOU CAN ANSWER THE QUESTION.

354 DR. DONALD DUTTON:

WELL, I HAVE INTERVIEWED FOUR PEOPLE WHO HAVE RECENTLY -- WHO HAVE RECENTLY COMMITTED HOMICIDES.

355 Q:

BY MR. BAILEY: AND DID YOU FIND CERTAIN CHARACTERISTICS ATYPICAL OF THEIR FORMER PERSONALITY THAT WERE PRESENT THAT YOU COULD TRIBUTE TO THE EXPERIENCE?

356 A:

THEY WERE SLIGHTLY -- WELL, THE PROBLEM IS THEY WERE REALLY SORT OF DIFFERENT HOMICIDES. TWO OF THEM WERE PARRICIDES. ONE OF THEM WAS A MAN WHO KILLED HIS WIFE AND TWO OF HIS KIDS AND THEN TRIED TO KILL HIMSELF AND THE GUN WOULDN'T FIRE. SO IT IS HARD TO SORT OF GO ACROSS COMMON CHARACTERISTICS FOR ALL OF THESE CASES.

357 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)
358 Q:

BY MR. BAILEY: WOULD YOU SAY THAT A TRAINED PERSON IN YOUR FIELD OR IN THE FIELD OF PSYCHIATRY, WHICH IS CLOSELY RELATED, IS IT NOT, WHO HAD INTERVIEWED 400 PEOPLE WHO HAD JUST COMMITTED A HOMICIDE WOULD BE OF VALUE IN ANALYZING THE PERSON YOU HAD BEFORE YOU?

359 A:

THEY SHOULD KNOW SOMETHING ABOUT IT.

360 Q:

THANK YOU. NOW, I BELIEVE IN YOUR DIRECT EXAMINATION YOU RELATED THE FACT AND YOU CERTAINLY HEARD ARGUMENT HERE THAT THE GAPS IN INCIDENTS MAY OR MAY NOT BE RELEVANT IN THE QUEST FOR AN ANSWER TO THE QUESTION OF BATTERING, TRUE?

361 A:

YES, YES.

362 Q:

ARE YOU SAYING THAT EVEN THOUGH PEOPLE ARE INTERACTING ON A REGULAR BASIS THAT THE INCIDENTS OF VIOLENCE MAY BE VERY WIDELY SPACED?

363 A:

THE INCIDENTS OF VIOLENCE MAY BE WIDELY SPACED WHILE OTHER FORMS OF ABUSE ARE OCCURRING IN THE INTERIM.

364 Q:

OKAY. THE OTHER FORMS BEING THE ECONOMIC ABUSE?

365 A:

AND THE EMOTIONAL ABUSE AND THE CONTROL.

366 Q:

OKAY. DID YOU, IN REVIEWING MATERIAL IN THIS CASE, HAVE HANDED TO YOU ANY DEPOSITIONS FROM THE DIVORCE PROCEEDINGS, JUST YES OR NO?

367 A:

YES, I DID.

368 Q:

INCLUDING THAT OF NICOLE BROWN SIMPSON?

369 A:

YES.

370 Q:

ALL RIGHT. DID YOU EXAMINE SOME DOCUMENTS THAT HAVE BEEN OFFERED UP BY THE PROSECUTION AS EXHIBITS IN THIS CASE, THOSE BEING LETTERS WRITTEN BY THE DEFENDANT AND STIPULATED TO AS HIS HANDWRITING, TO THE VICTIM OF THE 1989 INCIDENT?

371 A:

YES, I DID.

372 Q:

ALL RIGHT. AND DID YOU FIND THAT AS TO ONE OF THOSE, AN OFFER WAS MADE?

373 A:

YES.

374 Q:

"IF I EVER HIT YOU AGAIN I WILL TEAR UP THE PRENUPTIAL AGREEMENT"?

375 A:

YES.

376 Q:

DO YOU KNOW HOW MANY MILLIONS THAT AGREEMENT WAS WORTH ON THAT DATE?

377 A:

NO, I DON'T.

378 Q:

ASSUME THAT IT WAS WORTH SEVEN.

379 A:

OKAY.

380 Q:

ASSUME FURTHER THAT THE PROMISE WAS ATTESTED TO BY A LAWYER.

381 A:

UH-HUH.

382 Q:

AND WAS A VALID CONTRACT.

383 A:

UH-HUH.

384 Q:

AND ASSUME THAT FROM THAT DATE UNTIL JUNE 12, 1994, NO CLAIM WAS EVER MADE AGAINST IT.

385 A:

UH-HUH.

386 Q:

WOULDN'T YOU INFER FROM THAT THAT THERE WERE NO INCIDENTS THAT WOULD SUPPORT SUCH A CLAIM?

387 MR. GORDON:

OBJECT -- WITHDRAW THE OBJECTION.

388 DR. DONALD DUTTON:

I WOULD INFER FROM THAT THAT THERE WERE NO INCIDENTS OF PHYSICAL ABUSE TO SUPPORT THAT CLAIM, YES.

389 Q:

BY MR. BAILEY: OKAY. AND YOU DO KNOW THAT AS OF JUNE 11, 1992, THE VICTIM IN THIS CASE SAID "NOTHING HAS HAPPENED TO ME OF A PHYSICAL NATURE SINCE 1989"?

390 MR. GORDON:

OBJECT, ASSUMES A FACT NOT IN EVIDENCE, AND IT IS IRRELEVANT.

391 MR. BAILEY:

I HAVE PAGES OF DEPOSITION HERE IF YOU WANT ME --

392 MR. GORDON:

FINE, BUT IT GOES BEYOND WHAT THE COURT RULED THE SCOPE IS.

393 THE COURT:

SUSTAINED.

394 MR. BAILEY:

ALL RIGHT.

395 Q:

NOW, DOCTOR, I TAKE IT THAT IN THOSE CASES WHERE A HOMICIDE HAS TAKEN PLACE AND YOU WERE CONSULTED THAT THE QUESTION PUT TO YOU IS WHY? IS IT CONNECTED, IS IT RELATED TO PRIOR CONDUCT, ET CETERA?

396 A:

YES.

397 Q:

WHAT WAS THE MOTIVE, WHAT THEIR INTENT WAS?

398 A:

YES.

399 Q:

HAVE YOU ANY EXPERIENCE IN IDENTIFYING THE PERPETRATORS OF HOMICIDE BY VIRTUE OF RESORT TO THE SYNDROME?

400 A:

WHICH SYNDROME IS THAT?

401 Q:

THE SO-CALLED BATTERING SYNDROME WITH THE CHARACTERISTICS?

402 A:

I SEE. OKAY. NO.

403 Q:

ALL RIGHT. SO THAT YOUR EXPERTISE IS NOT IN DECIDING IF SOMEBODY COMMITTED AN ACT BUT GENERALLY WHY?

404 A:

THAT'S CORRECT.

405 Q:

AND VERY FRANKLY, IN YOUR ENTIRE SCIENCE NO ONE HAS DEFINED AN ABILITY TO ANSWER THE QUESTION "IF" AS AGAINST WHAT?

406 MR. GORDON:

ASSUMES A FACT NOT IN EVIDENCE, IF THAT HAS EVER BEEN A QUESTION.

407 THE COURT:

OVERRULED. DO YOU UNDERSTAND THE QUESTION?

408 DR. DONALD DUTTON:

COULD YOU SAY IT AGAIN?

409 MR. BAILEY:

YES.

410 Q:

DO YOU KNOW OF ANY STUDIES OR PUBLICATIONS OR LEARNED PAPERS THAT INSTRUCT YOU IN YOUR ILK AS TO WHAT STEPS TO TAKE IF SOMEONE COMES TO YOU --

411 A:

RIGHT.

412 Q:

-- WITH SOME FACT THAT MAY OR MAY NOT SUPPORT BATTERY AND ASK YOU TO USE THOSE TO IDENTIFY A PERPETRATOR RATHER THAN TO EXPLAIN HIS MOTIVATIONS? YOU SAY YOU HAVE NEVER DONE IT. I'M ASKING YOU IF THAT THERE ARE STUDIES THAT ENABLE PEOPLE TO DO IT?

413 A:

ANY STUDIES THAT ARE KIND OF CHECKLISTS TO A CERTAIN EXTENT THAT WOULD CAUSE A THERAPIST TO LEAN TOWARDS, YES, THIS PERSON PROBABLY HAD DONE IT, OR NO, THEY PROBABLY HAD NOT? IS THAT BASICALLY IT?

414 Q:

YEAH. I'M NOT --

415 A:

YES, THERE IS ONE. THERE IS ONE.

416 Q:

ONE CASE? ONE STUDY?

417 A:

WELL, THERE IS ONE STUDY, YES.

418 Q:

IS THAT SOMETHING THAT YOU WROTE?

419 A:

NO, I DIDN'T WRITE IT.

420 Q:

CAN YOU DEFINE IT FOR ME?

421 A:

IT IS ONE THAT HAS BEEN DEVELOPED BY DANIEL SONKIN WHO IS A CLINICAL PSYCHOLOGIST IN SAUSALITO. IT IS A LEGALITY CHECKLIST THAT HE HAS WORKED ON IN CASES OF THIS SORT.

422 Q:

OKAY. DO YOU KNOW IF DR. SONKIN HAS EVER CLAIMED THAT ABSENT ANY OTHER EVIDENCE IDENTIFYING A PERPETRATOR THAT ONE COULD DO IT FROM EVIDENCE OF A BATTERING SYNDROME?

423 A:

NOT JUST FROM A BATTERING SYNDROME ALONE, NO.

424 Q:

YOU WOULD RUN AN AWFUL RISK THAT SOMEBODY MIGHT HAVE AN IRONCLAD ALIBI?

425 A:

TOO MANY FALSE POSITIVES. TOO MANY FALSE POSITIVES.

KEY QUOTE
426 Q:

OKAY. SO BY THE WAY, DOCTOR, I ASKED YOU YESTERDAY INFORMALLY IF YOU COULD POINT ME IN THE DIRECTION OF SOME OF YOUR MANY WRITINGS THAT WOULD BE RELEVANT TO WHAT WE ARE HERE TO TALK ABOUT TODAY.

427 A:

RIGHT.

428 Q:

AND AT THAT POINT YOU WEREN'T SURE NOW WHY YOU WERE HERE TO DO THAT, RIGHT?

429 A:

THAT'S RIGHT.

430 Q:

BUT SINCE BEEN EDUCATED?

431 A:

THAT'S RIGHT.

432 Q:

CAN YOU NOW DEFINE WHICH OF YOUR WRITINGS WE MIGHT READ THAT WOULD HELP US ON THIS SUBJECT?

433 A:

NOT ONLY DO THAT, BUT I GUARANTEE TO GIVE YOU AN AUTOGRAPHED BOOK TOMORROW IN COURT.

KEY QUOTE
434 Q:

GOOD.

435 A:

AND A LIST OF EVERYTHING ELSE THAT MIGHT POSSIBLY BE RELEVANT. I HAVE ASKED TO HAVE A COUPLE OF BOOKS FED EX'D HAD DOWN BECAUSE I WANT YOU TO HAVE THEM.

436 Q:

THAT IS VERY KIND.

437 A:

I DIDN'T KNOW YESTERDAY EXACTLY WHAT DIRECTION I WOULD BE TESTIFYING.

438 Q:

I WILL TELL YOU WHAT, I WILL SWAP YOU OUT.

439 A:

IT IS A DEAL.

440 THE COURT:

MR. GORDON.

Temperature

tense

Key Quotes (5)

Dr. Donald Dutton
THE PSYCHOLOGICAL TESTS THAT WE HAVE USED TO DETERMINE WHETHER A MAN HAS WHAT WE CALL PROPENSITY FOR ABUSIVENESS OR NOT WERE NOT DESIGNED TO BE USED WITH A PERSON IN MR. SIMPSON'S CIRCUMSTANCES.
The prosecution's own expert concedes that standard diagnostic tools cannot fairly be applied to Simpson given his circumstances, undermining the scientific basis of the testimony.
Dr. Donald Dutton
TOO MANY FALSE POSITIVES. TOO MANY FALSE POSITIVES.
Dutton admits that using battering syndrome alone to identify a perpetrator is scientifically unreliable — a direct concession to Bailey's argument that the syndrome cannot prove Simpson committed murder.
F. Lee Bailey
I'M GIVING YOU A CONDOMINIUM, A PORSCHE, A MERCEDES AND A FERRARI, ALL IN YOUR NAME. IS THAT ECONOMIC CONTROL?
Bailey uses a thinly veiled hypothetical referencing OJ Simpson's documented gifts to Nicole Brown Simpson to get Dutton to admit this behavior is inconsistent with the economic control characteristic of batterers.
Dr. Donald Dutton
IF THERE WERE ABSOLUTELY NO STRINGS ATTACHED, THEN I WOULD AGREE WITH YOU, THAT THAT WOULD SEEM TO BE MAGNANIMOUS TO THE NTH DEGREE AND NOT A TYPE OF CONTROL.
Dutton concedes the hypothetical generous giving is not consistent with batterer economic control tactics, implicitly undermining the prosecution's characterization of Simpson.
Dr. Donald Dutton
NOT ONLY DO THAT, BUT I GUARANTEE TO GIVE YOU AN AUTOGRAPHED BOOK TOMORROW IN COURT... I HAVE ASKED TO HAVE A COUPLE OF BOOKS FED EX'D DOWN BECAUSE I WANT YOU TO HAVE THEM.
A disarming and collegial moment that punctuates an otherwise adversarial cross-examination, reflecting Dutton's cooperative demeanor under pressure.

Evidence (8)

Informal
Green evidence book ('Murder Book') reviewed by Dutton before testifying
discussed
Informal
Defense and prosecution briefs submitted to the court on the domestic violence evidence issue
discussed
Informal
Duluth, Minnesota Power and Control Wheel, included in prosecution's brief
discussed, challenged as diagnostic tool
Informal
Dr. Lenore Walker's book 'The Battered Woman' and her nine-characteristic checklists for battered women and batterers
read into record by Dutton during cross
Informal
Letters written by OJ Simpson (stipulated as his handwriting) to Nicole Brown Simpson following the 1989 incident, including promise to tear up prenuptial agreement if he hit her again
discussed
Informal
Grand jury testimony of Keith Zlomsowitch
confirmed Dutton had read it
+ 2 more

Notable Exchanges (5)

F. Lee BaileyDr. Donald Dutton
Bailey walks Dutton through a hypothetical — giving a woman a condo, a Porsche, a Mercedes, and a Ferrari with no strings attached — to establish that such generosity is inconsistent with batterer economic control. Dutton agrees it would be 'magnanimous to the nth degree and not a type of control.'
strategic
F. Lee BaileyDr. Donald Dutton
Bailey references the Zlomsowitch grand jury testimony directly, asking Dutton about a batterer who comes upon his ex-wife 'performing a sex act' and does nothing — then cordially greets the man the next day. Dutton agrees this would be 'atypical' for a jealous batterer. Judge intervenes before Bailey can press further.
revealing
F. Lee BaileyDr. Donald Dutton
Bailey draws on the prenuptial agreement — a $7 million promise by Simpson to tear it up if he ever hit Nicole again, attested by a lawyer — and asks whether the absence of any claim from that date through June 12, 1994 implies no physical incidents occurred. Dutton concedes: 'I would infer from that that there were no incidents of physical abuse to support that claim.'
strategic
F. Lee BaileyDr. Donald Dutton
Bailey introduces the Lady Byng Trophy (awarded in the NHL for skill with the least propensity for violence) and football captaincy (awarded for equanimity under assault) as proxies for OJ Simpson's public persona. Dutton counters by citing the dual personality characteristic and noting the principal dancer of the New York City Ballet had just been arrested for wife assault.
strategic
F. Lee BaileyScott GordonLance A. Ito
After Bailey tries to walk Dutton through Walker's nine battered woman characteristics as applied to Nicole Brown Simpson, Gordon objects and the judge sustains — but Bailey's framing (that the prosecution introduced the syndrome framework) is validated enough that he extracts the full characteristics list from Dutton before being cut off.
heated

Light Moments (4)

F. Lee Bailey
Bailey, mid-hypothetical about giving money to someone you love: 'I KNOW THAT IS A DELECTABLE THING TO CONTEMPLATE, BUT JUST TAKE IT HYPOTHETICALLY.'
F. Lee Bailey / Dr. Donald Dutton
Lengthy and affectionate digression into Canadian ice hockey, fighting at the blue line, and whether it's 'good for the gate' — culminating in Bailey asking if Bailey could be tried for manslaughter for hitting someone hard enough with a skate.
Dr. Donald Dutton / F. Lee Bailey
Dutton spontaneously offers to give Bailey an autographed copy of his book and have additional books FedExed to court. Bailey replies 'I WILL SWAP YOU OUT.' Dutton: 'IT IS A DEAL.'
Scott Gordon
Scott Gordon tells the judge: 'I DO FEEL IT A HONOR TO BE ABLE TO STAND UP IN COURT AND DISAGREE WITH MR. BAILEY.'

Credibility Attacks (3)

⚔ Dr. Donald Dutton
ethical standard / no personal examination
Bailey established at the outset that APA ethics require personal examination before giving an opinion about an individual, and that Dutton never examined Simpson. Dutton confirmed both, limiting his testimony to general syndrome characteristics rather than any opinion about Simpson specifically.
⚔ Dr. Donald Dutton
scope of expertise / inapplicability to identification
Bailey elicited that battering syndrome expertise is about explaining motivation and patterns, not identifying perpetrators — and that only one study (Sonkin's) even attempts the latter, with Dutton confirming it cannot be used on syndrome evidence alone due to 'too many false positives.'
⚔ Dr. Donald Dutton
inapplicability of diagnostic tools
Dutton conceded the psychological tests used to assess propensity for abusiveness 'were not designed to be used with a person in Mr. Simpson's circumstances' — his incarceration and pending charges — making formal diagnosis impossible and implicitly undercutting the value of his testimony.

Witness Demeanor

Cooperative and collegial throughout, often using conversational 'uh-huh' responses that prompted Judge Ito to intervene: 'WHEN YOU SAY UH-HUH DO YOU MEAN YES OR NO?'
Candid about limitations of his own science — volunteering that he lacked empirical data on escalation prediction without being pressed
Notably warm at the close, offering books and expressing genuine collegial interest in Bailey's line of inquiry

Objections

13 objections (2 sustained, 9 overruled)
Proceeding 4378 • 440 utterances • Prosecution witness
Criminal Trial
Department 103
⚖️ Start
📂 JAN 12, 1995 📄 Cross-examination of Dr. Donal
JAN 12, 1995 KRT DvH TD