
On November 21, 2025, the Nebraska Supreme Court cited Professor Joëlle Moreno’s law review comment, Killing Daddy: Developing a Self-Defense Strategy for the Abused Child (1989), 137 U.PA.L.REV. 1281, 1283. Professor Moreno’s interdisciplinary research supporting her finding that “[a]bused children perceive the behavior of their batterer with a degree of knowledge and familiarity not accounted for in the rational observation standard of the self-defense model” was cited by the court to support its conclusion that professional mental health evaluation is typically necessary to an accurate understanding of intrafamily violence.
