Cited by

401, 402; ¶ 16, 587 ¶ 20 (2017) (explaining “expert testimony that explains a victim’s seemingly inconsistent behavior is admissible to aid jurors in evaluating the victim’s credibility”); -74 (1986); –64 (1985) (noting expert testimony on response of rape victims was admissible where issue was lack of consent).

Expert witnesses may speak to general behavioral characteristics that affect credibility or accuracy, as long as they do not “give their opinion of the accuracy, reliability or credibility of a particular witness” or that of “witnesses of the type under consideration.” 475 (1986).

(explaining that when a party opens the door to improper evidence, “[a]ny error with respect to the admission of such .

“Such opinions are rejected[,]” this Court reasoned, “because they are ‘nothing more than advice to jurors on how to decide the case.’” Reimer, 189 Ariz. at 241 (); (“[E]xperts should not be allowed to give their opinion of the accuracy, reliability or credibility of a particular witness in the case being tried [because] .

A party opens the door for otherwise improper evidence to be introduced when “comments made by one party make otherwise irrelevant evidence highly relevant or require some response or rebuttal.”

¶37 Before trial, Winston opposed admission of other-act evidence related to the Globe case, which would ordinarily preserve the 10 STATE v. WINSTON Decision of the Court issue for appeal, –76 (1986).

to original 1977 rule; (“The law does not permit expert testimony on how the jury should decide the case.”).

See, (explaining that expert witnesses should not provide opinions about the credibility of another witness); –41 (App. 1997) (to same effect).

-75 (1986), to argue that while the cold expert was permitted to testify about general behavior patterns, the law precludes the use of expert testimony to establish accuracy, reliability, or credibility.

See State v. Lindsey , , 475, , 76 (1986) ("[W]e explicitly state at this time that trial courts should not admit direct expert testimony that quantifies the probabilities of the credibility of another witness.") (citing State v. Buell , 22 Ohio St.3d 124 , 489 N.E.2d 795 , 804 (1986) ); State v. Moran , , 385-86

(“[E]ven where expert testimony on behavioral characteristics that affect credibility or accuracy of observation is allowed, experts should not be allowed to give their opinion of the accuracy, reliability or credibility of a particular witness in the case being tried.”).

¶23 However, the statements made by the prosecutor in closing argument related to both the expert and the detective’s testimony about the percentage of cases in which they discovered that a victim had made a false accusation were a

(quoting Udall & Livermore § 11 at 11).

Psychologists and psychiatrists are not, and do not claim to be, experts at discerning truth.” –74 (1986) (distinguishing between permissible expert testimony about general behavioral characteristics of child molestation victims and impermissible opinion testimony about an alleged victim’s credibility); (“Arizona courts have expressly determined that neither e

But an “expert may neither quantify nor express an opinion about the veracity of a particular witness or type of witness.” Tucker, 165 Ariz. at 346; (noting that an 8 STATE v. HASKIE Opinion of the Court expert should not be “allowed to go beyond the description of general principles of social or behavioral science which might assist the jury in their o

See Salazar-Mercado, 234 Ariz. at 594, ¶ 15; ¶ 12 (1998); -74 (1986).

-74, see also Moran, 151 Ariz. at 382, 728 P.2d at 251.

(allowing a defendant’s statement “to be heard through the testimony of an [expert] would cloak it with undeserved authority that could unduly sway a jury”); –75, – 76 (1986).

-78 (1986) (affirming convictions on counts supported by overwhelming evidence even though improper expert testimony was admitted).