State v. Beauvais

Medical evidence of child sexual abuse is admissible in a criminal case if an expert is available to testify as to the probative value and meaning of the evidence.

Defendant appealed conviction of one count of first-degree sexual abuse on the ground that the trial court erred in denying his motion in limine to exclude expert witness testimony which Defendant argued impermissibly commented on a witness’s credibility. Specifically, Defendant moved to exclude “evidence of a diagnosis of child sexual abuse,” arguing that the evidence of such was irrelevant, invalid as scientific evidence, and unfairly prejudicial. Defendant’s conviction was affirmed by the Oregon Court of Appeals. The Court held that the medical evidence of child sexual abuse was admissible because the probative value of the evidence significantly outweighed the prejudicial effect the evidence had on Defendant, and that the expert needed to use the evidence in order to give testimony regarding the nature of medical sexual assault evaluation. Because the medical evidence was complicated and required an expert to testify as to its meaning, the Court found that the medical evidence was admissible. Thus, the Court determined that the trial court was correct to deny Defendant’s motion in limine to exclude the evidence of sexual abuse, and the decisions of the trial court and Court of Appeals were AFFIRMED.