In State v. Brown, the defendant, Brown, was convicted of first-degree sexual conduct with a minor, three counts of lewd acts committed upon a child, and three counts of first-degree sexual exploitation of a minor.
Brown appealed his convictions, arguing that the State’s expert witness, Shauna Galloway-Williams, should not have been allowed to testify as an expert and neither should her testimony have been admitted at trial. Lastly Brown contended that her testimony’s prejudicial effect outweighed its probative value so it should not have been admitted.
Galloway-Williams testified about symptoms of child abuse but acknowledged that she had never met any of the children involved in this case. The State insisted that Galloway-Williams did not testify as to the veracity of the children’s accusations. Instead she described child abuse symptoms.
The Court affirmed Brown’s conviction, holding that “…the circuit court properly admitted Galloway-Williams’ expert testimony regarding general behavioral characteristics of child sex abuse victims and delayed disclosures because the subject matter fell outside the realm of lay testimony. Moreover, we hold Galloway-Williams expert testimony did not improperly bolster the minor victims’ testimony because (1) she never met with the minor victims, (2) her knowledge of the case was limited to her discussions with the solicitor, (3) she did not comment on the credibility of the minor victims in the instant case, and (4) she did not express an opinion or belief regarding the credibility of child sex abuse victims’ allegations more generally.”