State v. Brown’s Empirical Analysis

Citation profile

10 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]he circuit court ... found that, based on the jurors’ qualifications and their responses to questions during voir dire, the empaneled jury “would not have any prior knowledge from family members or otherwise as to sex abuse directly.” At trial, Appellant cross-examined the minor victims extensively regarding their delays in disclosure as well as the varying accounts of the abuse they gave authorities. Indeed, the minor victims delayed disclosing the abuse for almost three years, were unable to recall specific days or dates on which they were abused, gave varying accounts of certain instances of abuse, and divulged more facts each time they spoke about the abuse. Such behavior undoubtedly became a fact at issue in this case, raising questions of credibility or accuracy that might not be explained by experiences common to jurors. Accordingly, we find Galloway-Williams’ specialized knowledge of the behavioral characteristics of child sex abuse victims was relevant and crucial in assisting the jury’s understanding of why children might delay disclosing sexual abuse, as well as why their recollections may become clearer each time they discuss the instances of abuse. Numerous jurisdictions considering this issue have similarly concluded it is more appropriate for an expert to explain the behavioral traits of child sex abuse victims to a jury. We believe the unique and often perplexing behavior exhibited by child sex abuse victims does not fall within the ordinary knowledge of a ”

   1 later decision quote this exact passage
   e.g. State v. Jones

2. “Expert testimony concerning common behavioral characteristics of sexual assault victims and the range of responses to sexual assault encountered by experts is admissible. Such testimony is relevant and helpful in explaining to the jury the typical behavior patterns of adolescent victims of sexual assault. It assists the jury in understanding some of the aspects of the behavior of victims and provides insight into the sexually abused child's often strange demeanor.” (citations omitted)); Brown, 411 S.C. at 341-42 , 768 S.E.2d at 251 (finding the expert’s”

   1 later decision quote this exact passage
   e.g. State v. Barrett

3. “the concerns our supreme court expressed in Kromah regarding forensic interviewers testifying as experts in child sexual abuse cases are inapplicable to the instant case because the danger of prejudice — which could result from the jury giving undue weight to the expert testimony of a forensic interviewer who interviews the victim and expresses an opinion as to the child’s credibility — is simply not present here.”

   1 later decision quote this exact passage
   e.g. State v. Jones