In this criminal case arising from the defendant allegedly striking the victim, the Colorado Supreme Court analyzed the circumstances when generalized expert testimony may be admitted based upon the helpfulness, or the “fit” of the expert testimony and factual issues in a case. Looking at the facts of this case, the Supreme Court determined that the generalized expert testimony on the dynamics of domestic violence, including kindness-violence dichotomy and power-and-control dynamic, was a sufficient fit and was admissible. In so holding, the Supreme Court noted that the fit of generalized expert testimony to a case need not be perfect for testimony to be admissible, and each aspect of the testimony need not match a factual issue presented in the case. More particularly, the Supreme Court found that, when certain behaviors by a domestic violence victim are in conflict with what an ordinary juror might intuitively expect, generalized expert testimony can be helpful to educate the jury on what social science teaches about those behaviors.

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