State v. Christopher Robins, 297 P.3d 1213

Robins was convicted of molesting his step-daughter (C.G.), who was 13–14 during the abuse and trial, with multiple acts including touching, oral sex, and attempted intercourse.
The alleged abuse occurred spring–fall 2010, with the note from C.G. October 29, 2010 noting abuse; the note was found by her mother.
The State filed a Notice of Expert designating Wendy Dutton as a child-sex-abuse expert to testify on victimology, grooming, disclosure, interviewing, and credibility considerations.
Robins moved to preclude Dutton’s testimony; the district court admitted the testimony with a cautionary jury instruction limiting its use to pattern recognition and not as an opinion on credibility.
The district court later dismissed one count for lack of jurisdiction and Robins was sentenced to 30 years on the remaining convictions, all consecutive; Robins appealed challenging the expert testimony ruling.
The Montana Supreme Court affirmed the convictions, holding that the expert testimony was admissible under M.R.Evid. 702 and did not directly comment on C.G.’s credibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by admitting Dutton’s testimony	State contends admission was proper under Rule 702	Robins argues testimony invaded jury credibility assessment	No abuse; testimony admissible under Rule 702 with cautionary instruction

State v. Harris, 247 Mont. 405 (1991) (limits on expert credibility testimony; direct credibility comments allowed only in narrow youth cases)
State v. Morgan, 291 Mont. 347 (1998) (educational expert testimony on child abuse patterns; not direct credibility opinion)
State v. Scott, 850 P.2d 292 (1993) (expert educational testimony to assist jury; not direct credibility ruling)
State v. Hensley, 821 P.2d 1032 (1991) (exception for young child victims’ credibility in limited circumstances)
State v. J.C.E., 767 P.2d 309 (1988) (overruled in part; credibility considerations in expert testimony)