Pennsylvania v. Jones Jr. (majority)Annotate this Case
Appellant Rod Jones, Jr. was charged with rape and various sexual offenses following allegations by his stepdaughter (“the victim”) of repeated sexual abuse over a period of several years. According to the victim, the first instance of abuse occurred when she was thirteen year sold. The victim did not tell anyone about these incidents for many years. because Appellant told her no one would believe her. The victim also feared what Appellant would say about her to her mother. When the victim was seventeen years old, she eventually told her mother about the abuse. Throughout the trial, defense counsel focused on discrepancies in the victim’s recounting of events in an attempt to undermine her credibility. At one point, the Commonwealth called as a witness Detective Scott Holzwarth, who interviewed the victim during the course of the investigation. The jury ultimately found Appellant guilty of rape, involuntary deviate sexual intercourse with a person under sixteen years of age, unlawful contact with a minor, aggravated indecent assault, sexual assault, statutory sexual assault, endangering the welfare of a child, corruption of minors, and indecent assault of a person under sixteen years of age. The trial court sentenced Appellant to an aggregate term of twenty-seven to sixty years’ imprisonment. Appellant filed a post-sentence motion, which the trial court denied. On appeal, Appellant argued, inter alia, that the trial court abused its discretion by allowing Detective Holzwarth to testify that child sexual assault victims were often unable to recall specific details and dates of sexual assaults. The Supreme Court found that expert testimony on the issue of a witness’s credibility was impermissible, as it encroached on the province of the jury to make such determinations. "While some testimony on this topic may be prohibited for impermissibly invading the jury's province of determining credibility, we disagree that all testimony will." The Court held that whether Detective Holzwarth's testimony complied with admissibility considerations was a question for the trial court upon remand. The superior court's judgment was reversed and the matter remanded for a new trial.