Smith's Criminal Case Compendium
Table of Contents
State v. Watts, 246 N.C. App. 737 (Apr. 5, 2016)
The defendant did not establish plain error with respect to his claim that the State’s expert vouched for the credibility of the child sexual assault victim. The expert testified regarding the victim’s bruises and opined that they were the result of blunt force trauma; when asked whether the victim’s account of the assault was consistent with her medical exam, she responded that the victim’s “disclosure supports the physical findings.” This testimony did not improperly vouch for the victim’s credibility and amount to plain error. Viewed in context, the expert was not commenting on the victim’s credibility; rather she opined that the victim’s disclosure was not inconsistent with the physical findings or impossible given the physical findings.