State v. Batangan
Supreme Court of Hawaii
799 P.2d 48 (1990)
Felomino Batangan (defendant) was charged with sexually abusing his daughter (the victim) when she was six or seven. The victim could not give specific dates and did not report the abuse until months later, first accusing him of physical abuse to school officials, then recanting that and accusing him of sexual abuse, then recanting again before ultimately testifying to the sexual abuse at trial. There were no witnesses to the alleged acts. At trial, the prosecution's expert, Dr. John Bond, a clinical psychologist specializing in sexually abused children, described how he evaluates whether a child is telling the truth about abuse and then, in substance, told the jury he found the victim credible and believed Batangan had abused her. Batangan was convicted of first-degree sexual abuse and appealed.
Whether an expert may testify, in a child sex-abuse case, as to whether he personally believes the victim's account of the abuse.