State v. J.R., 152 A.3d 180

Background

Defendant J.R. was convicted of multiple sexual offenses against his step‑granddaughter N.R., who first disclosed the abuse to her brothers years after it began and later to her parents; no independent eyewitnesses to the assaults testified.
The State called CSAAS expert Dr. Lynn Taska (over defense objection) to explain why abused children might delay reporting, recant, or behave in varied ways; the trial court limited CSAAS testimony per the Model Jury Charge.
Dr. Taska, testifying first for the State, described the five CSAAS components and—in a brief passage—outlined an expansive spectrum of behaviors (from highly well‑adjusted to acting‑out/sadistic) manifested by some abuse victims; she also referenced the Penn State/Sandusky case.
The jury heard detailed, consistent testimony from N.R., corroboration on access/fresh‑complaint from family members, and impeaching inconsistencies in defendant’s statements; defendant was convicted and sentenced to lengthy terms.
The Appellate Division reversed, holding the CSAAS expert exceeded permissible bounds (including the Penn State reference) and that the error was not harmless; the Supreme Court granted limited certification.
The Supreme Court held the expert’s testimony in part exceeded authorized CSAAS limits but that the error was harmless given N.R.’s compelling testimony, family corroboration, impeachment of defendant, and strong limiting instructions; it reversed the Appellate Division and remanded for consideration of other issues.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility/scope of CSAAS testimony under N.J.R.E. 702	CSAAS expert may generally explain why abused children delay reporting; Taska’s general range explanation was proper and non‑diagnostic	CSAAS limited to explaining delayed disclosure/recantation only; expert may not describe behaviors in a way that invites inference of victim credibility or defendant’s guilt	Expert testimony improperly exceeded narrow CSAAS bounds by describing a sweeping range of behaviors and citing Penn State, but those departures were brief and not outcome‑determinative (error was harmless)
Whether expert testimony improperly opined on victim credibility or guilt	State: expert did not connect testimony to this victim or opine on guilt; limiting instructions were given	Defendant: testimony encouraged jurors to treat described behaviors as substantive proof that N.R. was abused	Court: Taska did not explicitly connect CSAAS to N.R. or opine on guilt; still cautioned such testimony risks inference to credibility and must be narrowly circumscribed
Timing/order of expert testimony	State: scheduling/strategy permitted calling expert first	Defendant: calling CSAAS expert before the child risks overstating expert’s role and misleading jury	Court: as a general practice CSAAS experts should not be the State’s initial witness; their rehabilitative role is to follow the child’s testimony
Harmless‑error analysis of CSAAS overreach	State: case proved by strong eyewitness (victim) testimony and corroboration; any error was harmless	Defendant: prosecution relied heavily on victim testimony so CSAAS overreach was prejudicial	Court: error was harmless — victim’s testimony, family corroboration, defendant’s admissions and impeachment made unjust result unlikely

Key Cases Cited

State v. J.Q., 130 N.J. 554 (1993) (introduced CSAAS limits; expert may not opine that a particular child was abused)
State v. P.H., 178 N.J. 378 (2004) (CSAAS is rehabilitative to explain delayed disclosure; model jury charge guidance)
State v. R.B., 183 N.J. 308 (2005) (CSAAS expert must not relate syndrome attributes to the specific child; narrowly circumscribe testimony)
State v. W.B., 205 N.J. 588 (2011) (disapproved statistical credibility testimony; reiterated strict limits on CSAAS)
State v. Kelly, 97 N.J. 178 (1984) (N.J.R.E. 702 reliability framework for expert testimony)
State v. Macon, 57 N.J. 825 (1971) (harmless‑error standard: reversal only if error is clearly capable of producing unjust result)