State of Iowa v. Matthew Eugene Brown, 2014 Iowa Sup. LEXIS 102

Defendant Matthew Brown charged with sexual abuse in the second degree under Iowa Code 709.1 and 709.3(2) (2011); jury convicted Brown.
Appeals: Brown argued the expert testimony vouched for the victim’s credibility; court of appeals granted a new trial; we granted further review.
A.T. attended a sleepover at Brown’s home; she and siblings slept on the living room floor; Brown touched A.T.’s vagina with his hand while others slept.
Forensic interviewer Mattox and Dr. Harre examined A.T.; Harre’s medical report stated A.T.’s history was detailed and consistent and warranted investigation.
Motions in limine sought to exclude Harre’s statements as hearsay and as Confrontation Clause issues; district court admitted part of Harre’s report; closing arguments referenced Harre; jury convicted; court denied new trial; court of appeals reversed; we granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by admitting the challenged paragraph from Harre’s report.	Brown argues the paragraph improperly vouches for credibility.	Brown contends the paragraph invades the jury’s role by endorsing AT’s credibility.	Yes; admission was an abuse of discretion and requires reversal for a new trial.

State v. Dudley, 856 N.W.2d 668 (Iowa 2014) (admissibility of expert vouching for credibility)
State v. Myers, 382 N.W.2d 91 (Iowa 1986) (limits on expert credibility testimony)
State v. Dudley (repeat), 856 N.W.2d 668 (Iowa 2014) (explicitly discusses non-credibility commentary by experts)
Graber v. City of Ankeny, 616 N.W.2d 633 (Iowa 2000) (reasonableness of grounds for evidentiary rulings)