Durfee is the most recent in a series of child abuse cases indicating the court's effort to protect the safety of children without sacrificing the due process rights of the defendants. In Durfee, the defendant was convicted of first-degree assault on a child by evidence that was primarily circumstantial. The court recognized the discrepancy between the parent's or custodian's explanation of the injuries and the medical testimony on what circumstances could have caused the injuries as the crucial factor in identifying battered child syndrome. Durfee claimed that the introduction of testimony concerning battered child syndrome violated due process rights and shifted the burden of proof from the state to the defendant. Although the use of battered child syndrome testimony may have the effect of prejudicing the jury, Durfee's due process argument was properly rejected by the court. The testimony of the state was consistent with the principles set in prior cases. The jury was instructed that the defendant was presumed innocent until proven guilty beyond a reasonable doubt; and the state met both burdens of going forward with the evidence and of proof with the aid of an accepted medical diagnosis of battered child syndrome. State v. Durfee reflects society's increased awareness of the necessity of protecting the health and welfare of children, while placing safeguards on the use of a powerful form of circumstantial evidence -expert testimony identifying battered child syndrome.