State v. Salazar-Mercado

Martin Salazar-Mercado (defendant) was charged with child molestation, and the alleged victims had delayed reporting the abuse and could not remember certain details at trial. The prosecution called Dr. Wendy Dutton to testify generally about Child Sexual Abuse Accommodation Syndrome (CSAAS) to help the jury understand typical behavior patterns of child-molestation victims, without connecting her testimony to the specific facts of this case. Salazar-Mercado moved to exclude her as an impermissible "cold" expert; the trial court denied the motion, and he was convicted and appealed.