Anthony R. Beard v. State of Arkansas, 594 S.W.3d 29

Anthony Beard was tried for multiple sexual offenses involving three girls (M.L., T.M., J.C.) who had known him; victims testified to similar, detailed instances of sexual abuse and assault.
Jessica Bragg, an investigator with the Crimes Against Children Division, interviewed the children at the Child Advocacy Center and testified at trial.
On direct examination Bragg stated she found the allegations "true" and that the three victims were "very credible," over defense objections citing Cox v. State.
The State also called the three victims; there were no independent eyewitnesses or physical evidence supporting the allegations.
The jury convicted Beard of rape of T.M. and two counts of second-degree sexual assault (M.L. and J.C.); Beard was sentenced to life plus 40 years and appealed.
The Arkansas Supreme Court reversed and remanded, holding the investigator's credibility statements improperly bolstered the victims and the error was not harmless where the case turned on their credibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an investigator may testify that she found allegations "true" and that victims were "very credible"	State: Although admission was error, it was harmless because victims gave similar, graphic, detailed testimony amounting to overwhelming evidence	Beard: Such testimony invades the jury's province, improperly bolsters victims, and is barred by Cox	The court: Admission was error; testimony directly bolstered credibility and was not harmless because convictions rested solely on victims' testimony; reverse and remand
Whether the error was harmless	State: Error slight; evidence of guilt overwhelming (consistent, graphic accounts from three victims)	Beard: Prejudice is likely because the only supporting evidence was victims' testimony	The court: Error not harmless under harmless-error standard where the main evidence is victim testimony without independent corroboration

Montgomery v. State, 2014 Ark. 122 (witness opinion on victim truthfulness generally inadmissible)
Cox v. State, 93 Ark. App. 419 (forensic interviewer’s credibility opinion not harmless where case depended on victim credibility)
Buford v. State, 368 Ark. 87 (similar testimony held harmless where independent eyewitness corroboration made any prejudice slight)
Johnson v. State, 292 Ark. 632 (doctor’s testimony that victim was telling the truth found prejudicial where evidence was not overwhelming)
Logan v. State, 299 Ark. 255 (medical experts’ statements on victim credibility were prejudicial error)
Rogers v. State, 2018 Ark. 309 (reversal where only supporting evidence was victims’ testimony and exclusion of impeachment evidence was erroneous)
Russell v. State, 289 Ark. 533 (credibility-related testimony harmless where physical evidence strongly corroborated victim)
Brown v. State, 374 Ark. 341 (uncorroborated rape-victim testimony can suffice for conviction)
Kelley v. State, 2009 Ark. 389 (similar conduct by defendant emphasized as probative on credibility and consistency)