Cited by

Generally, district courts must “reject expert opinion testimony regarding the truth or falsity of a witness[’s] allegations about a crime, for the expert’s status may lend an unwarranted ‘stamp of scientific legitimacy’ to the allegations.” ( (Mich.

the supreme court identified the importance of expert testimony in child sexual-abuse cases: The nature .

Nor should the credibility of witnesses in criminal trials turn on the outcome of a battle among experts.”

“It is well -settled that a conviction can rest on the uncorroborated testimony of a single credible witness.” (stating that “in a prosecution for criminal sexual conduct the complainant’s testimony need not be corroborated”).

-10 (Minn. 1984) (explaining that “[w]ith respect to most crimes the credibility of a witness is peculiarly within the competence of the jury, whose common experience affords sufficient basis for the assessment of credibility”).

To the extent that Schaefer-Bonovsky raises this issue in his self-represented brief, and assuming that this issue is properly before us on the merits, we conclude that Mitnick did not present vouching testimony because her testimony, which provided insight into the conduct of child sexual -abuse victims

He relies on the general rule that courts must “reject expert opinion testimony regarding the truth or falsity of a witness[’s] allegations about a crime, for the expert’s status may lend an unwarranted ‘stamp of scientific legitimacy’ to the allegations.”

“Corroboration of an allegation of sexual abuse of a child is required only if the evidence otherwise adduced is insufficient to sustain conviction.”

But “in a prosecution for criminal sexual conduct the complainant ’s testimony need not be corroborated.” State v. Myers , see also Minn. Stat. § 609.347, subd.

(concluding evidence was sufficient when “primary evidence” was victim’s “word and evidence of behavioral change”); -08 (Minn. 1984) (concluding evidence was sufficient when victim gave “detailed description of the manner in which [defendant] perpetrated the abuse”).

in contending that the social worker’s education and skills do not qualify her to “opine on 18 psychology or the behaviors, tendencies or capacities of disabled children.” In Myers, the supreme court considered testimony from a clinical psychologist with a Ph.D.

Further, expert testimony providing “relevant insight into the puzzling aspects of [a] child’s conduct and demeanor which the jury could not otherwise bring to its evaluation of [a child’s] credibility is helpful and appropriate in cases of sexual abuse of children.”

d 604, 610 (Minn. 1984).

—for example, delayed disclosures—[is] not a common understanding for adults.” -11 (Minn. 1984), which held that expert testimony about the behavior and characteristics typical of sexually abused adolescents can be admissible because it is outside the common experience of a jury; and 5 -13 (Minn. App. 2017)

Portillo contends that the evidence supporting the jury’s guilty verdict is not strong because the State “failed to present any evidence corroborating J.G.’s testimony.” We have long recognized that “in a prosecution for criminal sexual conduct the complainant’s testimony need not be corroborated.” see also Minn. Stat. § 609.347, subd.

See Vick, d at 689; -11 (Minn. 1984).

Thus, this is not a case “that may well call for a holding that there is insufficient evidence.” Id.; (concluding that the child victim’s testimony was corroborated “to some extent” by the testimony of the child’s mother, a social worker, and a psychologist); (holding that the evidence was sufficient to sustain criminal- sexual-conduct convictio

v. Myers, (“Background data providing a relevant insight into the puzzling aspects of the child’s conduct and demeanor which the jury could not otherwise bring to its evaluation of her credibility is helpful and appropriate in cases of sexual abuse of children .

rier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise.” “The basic consideration in admitting expert testimony under [rule 702] is whether it will assist the jury in resolving the factual questions presented.”

See, -10 (Minn. 1984) (observing that the behaviors of child victims of sexual abuse may be outside the common experience of a jury and concluding that expert testimony concerning the traits and characteristics typically found in sexually abused children was therefore properly admitted).

Two years later, the supreme court considered an appeal in which the appellant was convicted of engaging in second-degree criminal sexual conduct toward a child who was six or seven years old.

701 (allowing lay-opinion testimony if “helpful to a clear understanding of the witness’ testimony or the determination of a fact in issue”); d 604, 609 (Minn. 1984) (discussing rule 702).

But the supreme court has recognized that the nature of “the sexual abuse of children places lay jurors at a disadvantage.”

1); (“Corroboration of an allegation of sexual abuse of a child is required only if the evidence otherwise adduced is 8 insufficient to sustain conviction.”).

See, (complainant said that the d efendant would “touch her on her ‘chest’ and between her legs”); (child/juvenile victims referred to different parts of anatomy by various euphemisms); (victim

The supreme court has held that the nature of child sexual abuse places lay jurors at a disadvantage, because a jury may not have the necessary background to assess the credibility of an adolescent victim of sexual abuse.

See State v. Myers , (determining that even with no physical evidence t o corroborate a victim’s testimony, other witness testimony supporting the date and time of an alleged incident, and testimony that provided support f or the consistent and positive nature of the victim’s statements, provided some corroboration)

“Corroboration of an allegation of sexual abuse of a child is required only if the evidence otherwise adduced is insufficient to sustain conviction.”

-11 (Minn. 1984) (stating that the “cause of many physical and emotional ailments” that “cannot be demonstrated to an absolute certainty” are “nevertheless, the subject of expert testimony”).

at 639 (citing State v. Myers , ).

702 is whether it will assi st the jury in resolving the factual questions presented.” State v. Meyers

we would reject expert opinion testimony regarding the truth or falsity of a witness’[s] allegations about a crime, for the expert’s status may lend an unwarranted stamp of scientific legitimacy to the allegations.” (quotation omitted).

Generally, we “reject expert opinion testimony regarding the truth or falsity of a witness’ allegations about a crime.”

(noting that issues concerning reliability of an expert’s testimony “goes not to the admissibility of the testimony but to its relative weight.”) Appellant had the opportunity to challenge the expert’s reliability and the weight to be given to the testimony by cross-examining her extensively on t

-10 (stating the credibility of witnesses is within the competence of the jury).