in Interest of J.R

2021 COA 81
CourtColorado Court of Appeals
DecidedJune 10, 2021
Docket17CA2076, People
StatusPublished
Cited by1,013 cases

This text of 2021 COA 81 (in Interest of J.R) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Interest of J.R, 2021 COA 81 (Colo. Ct. App. 2021).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY June 10, 2021

2021COA81

No. 17CA2076, People in Interest of J.R. — Juvenile Court — Delinquency — Sexual Assault on a Child — Indecent Exposure; Evidence — Opinions and Expert Testimony — Testimony of Experts — Evidence of Character and Conduct of Witness

After a jury trial, the juvenile defendant was adjudicated

delinquent for acts that if committed by an adult would constitute

sexual assault on a child and indecent exposure. On appeal, he

contends that the juvenile court plainly erred in allowing a medical

doctor to testify that, based solely on one of the child victim’s

allegations, she had diagnosed that victim with “sexual abuse.” A

division of the court of appeals holds that the doctor’s expert

testimony impermissibly bolstered the victim’s credibility and

usurped the jury’s role as fact finder. However, the division

concludes that the error, while obvious, does not cast serious doubt

on the reliability of the jury’s verdict. And because the division rejects the juvenile’s other argument concerning prosecutorial

misconduct, it affirms the judgment. COLORADO COURT OF APPEALS 2021COA81

Court of Appeals No. 17CA2076 City and County of Denver Juvenile Court Nos. 15JD925 & 15JD945 Honorable Laurie A. Clark, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of J.R.,

Juvenile-Appellant.

JUDGMENT AFFIRMED

Division II Opinion by JUDGE HARRIS Román and Lipinsky, JJ., concur

Announced June 10, 2021

Philip J. Weiser, Attorney General, Daniel J. De Cecco, Assistant Attorney General Fellow, Denver, Colorado, for Petitioner-Appellee

Megan A. Ring, Colorado State Public Defender, Ryann S. Hardman, Deputy State Public Defender, Denver, Colorado, for Juvenile-Appellant ¶1 After a jury trial, J.R. was adjudicated delinquent for acts

against two victims that, if committed by an adult, would constitute

sexual assault on a child and indecent exposure.

¶2 On appeal, his primary argument is that the juvenile court

plainly erred by allowing a medical doctor to testify that, based on

one victim’s statements, she had diagnosed the victim with “sexual

abuse.” Although we conclude that the juvenile court erred, we also

conclude that admission of the testimony did not constitute plain

error warranting reversal. And because we reject J.R.’s other

argument concerning prosecutorial misconduct, we affirm.

I. Background

¶3 The charges against J.R. arose from allegations made by A.M.

and her cousin E.P. After A.M.’s parents separated, she stayed part

of each week with her father (E.P.’s uncle), who lived with his

girlfriend and her son, J.R.

¶4 In 2011, when A.M. and E.P. were both eight years old and

J.R. was thirteen, A.M. told her mother that J.R. had touched her

vaginal area. During a subsequent forensic interview, A.M.

described sexual contact by J.R. and said that E.P. had been

present when it occurred. Following the allegations, the girls were

1 no longer permitted to stay overnight at father’s home, but their

parents allowed them to visit after school when father was there.

¶5 Four years later, during an argument in which her parents

angrily confronted her about her troubling behavior, E.P. reported

that J.R. had been sexually abusing her for years. In additional

forensic interviews, the girls reported multiple instances of sexual

abuse by J.R. The prosecution filed delinquency petitions charging

J.R. with six counts of sexual assault on a child, two counts of

indecent exposure, and six aggravated juvenile offender sentence

enhancers.

¶6 Both A.M. and E.P. testified at trial, and their recorded

forensic interviews were admitted into evidence. Family members

described the victims’ outcries and a social worker provided context

for the girls’ statements and conduct.

¶7 Through counsel, J.R. denied any abuse. The defense argued

that the abuse would have been seen or heard by one of the adults

who was always present when the girls visited father’s home. The

defense’s theory was that A.M. had fabricated the allegations as

part of her mother’s plan to obtain sole custody, and that E.P. had

2 fabricated the allegations to deflect attention from, and to avoid the

consequences of, her own bad behavior.

¶8 The jury found J.R. guilty on all counts.

II. Expert Witness Testimony

¶9 J.R. contends that the juvenile court erred by admitting a

medical doctor’s testimony that, based only on E.P.’s consistent

statements, she had diagnosed E.P. with “sexual abuse.”

A. Additional Background

¶ 10 At trial, Dr. Katherine Snyder, a child abuse pediatrician,

testified as an expert in the areas of pediatric medicine and child

sexual assault. Her testimony focused on her examination of E.P.

¶ 11 According to Dr. Snyder, “concerns had been raised” that E.P.

had been sexually abused, and Dr. Snyder was brought in to “do

the medical piece of the evaluation.” She testified that a sexual

abuse exam and diagnosis follows the same procedure as any other

medical exam and diagnosis — it includes a “head-to-toe” physical

examination and a discussion with the patient and family to obtain

a medical and social history.

¶ 12 In E.P.’s case, Dr. Snyder asked the victim only limited “basic

questions” because E.P. had already undergone a forensic interview,

3 and the doctor did not “want to make her go through all of those

details again.” Dr. Snyder testified that during the exam, E.P.

reported that J.R. had penetrated her vagina with his penis,

causing pain and bleeding.

¶ 13 E.P.’s physical examination was “normal,” according to Dr.

Snyder, with no signs of physical trauma. She explained, however,

that E.P. tested positive for bacterial vaginosis, a condition typically

associated with sexual intercourse but not necessarily a sign of

sexual abuse.

¶ 14 The prosecutor then asked Dr. Snyder if she had made a

diagnosis:

[PROSECUTOR]: So, at the conclusion of your examination with [E.P.], did you reach any sort of diagnosis?

[DR. SNYDER]: I did.

[PROSECUTOR]: Okay. What was your diagnosis?

[DR. SNYDER]: I diagnosed her with sexual abuse.

[PROSECUTOR]: Okay. Can you explain that to the jury.

[DR. SNYDER]: Yes. So, as we just talked about, we don’t need physical findings, right, to diagnose sexual abuse. If you read the most

4 up-to-date literature, technically all you need is consistent disclosure, meaning the child has told you something, and it’s not just told you something, but it’s really this child had told the same information to multiple people by the time she had seen me, and the information she told me was the same information she had told other individuals, including people not within her family. So, it was like in her forensic interview, like independent sources.

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2021 COA 81, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-interest-of-jr-coloctapp-2021.