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State v. Salazar-Mercado

Arizona Supreme Court
325 P.3d 996 (Ariz. 2014)


Martin Salazar-Mercado (defendant) was charged with child molestation. The alleged victims delayed reporting the abuse to authorities and could not remember certain details about the molestation when asked at trial. The prosecution called Dr. Wendy Dutton as an expert witness. Dutton sought to testify generally about Child Sexual Abuse Accommodation Syndrome (CSAAS) in order to educate the jury on the typical behavior of child-molestation victims. Salazar-Mercado filed a motion to exclude Dutton’s testimony, arguing that Dutton was a “cold” expert who would merely educate the jury on CSAAS without any direct link to the facts of the case. The trial court denied Salazar-Mercado’s motion. Salazar-Mercado was convicted, and he appealed.

Rule of Law


Holding and Reasoning (Timmer, J.)

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