P. v. Sedano
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Defendant was convicted of several sex offenses against Jane Doe, his adoptive niece: oral copulation or sexual penetration of a child ten years old or younger (count 2), sexual intercourse or sodomy with a child ten years old or younger (count 3), and forcible rape (count 4). He argued that (1) the conviction on count two must be reversed as violating the prohibition on ex post facto laws, an argument which the People concede; (2) the trial court erred in admitting expert testimony on child sexual abuse accommodation syndrome (CSAAS) statistics, or, in the alternative, that he received ineffective assistance due to his trial counsel’s failure to object to the statistics testimony; and (3) his aggregate indeterminate sentences on counts 2 and 3 are unconstitutionally excessive.
The Fifth Appellate District, in the published portion of the court’s opinion, held that the admission of the expert’s testimony regarding CSAAS statistics was not an error. In the unpublished portion, the court reversed the conviction on count two and remanded for possible retrial on that count, but the court did not otherwise reach the constitutional challenge. The court explained that there was no error in admitting the expert’s CSAAS statistical testimony about the prevalence of preexisting relationships between abuser and abused because the testimony targeted a common misconception regarding child sexual abuse. That CSAAS statistic thus served the permissible purpose of helping the jury evaluate Doe’s credibility, free of preconceived misconceptions, while not relieving jurors of their ultimate duty to independently determine the truthfulness of her testimony.
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