State v. Berry, 413 S.C. 118

Berry was convicted of second-degree CSC with a minor after a trial in Feb. 2013.
Indicted July 2012; trial followed a lengthy alleged pattern of abuse beginning May 2010.
Victim testified Berry abused her at his homes and near church, including acts after she turned sixteen.
The State presented expert Roseborough on trauma; defense objected under Kromah and Lyle-based reasoning.
Berry challenged the admissibility of subsequent bad acts and the expert testimony on PTSD and victim behavior.
Court upheld conviction, ruling no abuse of discretion in admitting bad act evidence or expert testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether subsequent bad act testimony was admissible	Berry argues acts after age sixteen exceed indictment scope; not relevant.	State relied on Rule 404(b) and common scheme to connect acts.	Admissible as a common scheme/plan, not abuse of discretion.
Whether expert PTSD/behavior testimony was admissible (Kromah)	Testimony vouches for credibility; improper under Kromah.	Uniformly admissible behavioral/trauma testimony; non-bolstering.	Not an abuse; admissible and not improper bolstering.

State v. Clasby, 385 S.C. 148 (2009) (admissibility and relevance framework for 404(b) evidence)
State v. Whitener, 228 S.C. 244 (1955) (common scheme/plan in sexual crimes)
State v. McClellan, 283 S.C. 389 (1984) (common scheme or plan in CSC cases)
State v. Weaverling, 337 S.C. 460 (1999) (admissibility of behavioral testimony in sexual abuse cases)
State v. Hudnall, 293 S.C. 97 (1987) (initial view on behavioral evidence in sexual abuse cases)
State v. Schumpert, 312 S.C. 502 (1993) (rape trauma evidence admissibility balance)
Kromah, 401 S.C. 340 (2013) (forensic interviewers may testify about behavior; cannot opine on credibility)
State v. White, 382 S.C. 265 (2009) (admission of expert testimony on trauma-related behavior permissible)