Whether preclusion of an accused citizen's PTSD diagnosis, proffered to support her self-defense claim, unconstitutionally impinges on her Due Process guarantee of a meaningful opportunity to present a complete defense

QUESTIONS PRESENTED FOR REVIEW Petitioner was sentenced to natural life in prison following a jury’s verdict finding her guilty of her live-in boyfriend’s premeditated murder. Petitioner sought to present evidence of her PTSD diagnosis and general evidence of the pregnancy hormone cortisol’s effects to bolster her claim of self-defense at trial.1 The trial court precluded Petitioner’s proffered testimony from two mental health professionals who | evaluated Petitioner following the killing and diagnosed Petitioner with Post | Traumatic Stress Disorder (PTSD). Additionally, the trial court precluded | Petitioner’s proffered evidence from an additional expert on the general psychological effects of the hormone cortisol during pregnancy. “Whether rooted directly in the Due Process Clause of the Fourteenth Amendment, or in the Compulsory Process or Confrontation clauses of the Sixth Amendment, the [United States] Constitution guarantees criminal defendants ‘a meaningful opportunity to present a complete defense.” Crane v. Kentucky, 476 U.S. 683, 690, 106 S.Ct. 2142 (1986), quoting California v. Trombetta, 467 U.S. 47 9, 485, 104 S.Ct. 2528 (1984). This case presents the following questions: Does preclusion of an accused citizen’s PTSD diagnosis, proffered to support her self-defense claim, unconstitutionally impinge on her Due Process guarantee of a meaningful opportunity to present a complete defense? * Petitioner was 9 months pregnant at the time of her boyfriend’s fatal shooting. i Is a PTSD diagnosis proper “observation evidence”, or does such a diagnosis constitute inadmissible “opinion testimony” under Clark v. Arizona, 548 U.S. 745, 126 S.Ct. 2709 (2006)? Did the Arizona Court of Appeals err, and thus again violate Petitioner’s Due Process right to present a complete defense, in categorizing Petitioner’s proffered evidence of cortisol’s effects as inadmissible diminished capacity | evidence? | | Wl