State v. J. Reams, 477 P.3d 1118

Joshua Reams was charged with one count of incest for alleged sexual abuse of his ten-year-old stepdaughter, J.L., and was convicted by a Jefferson County jury.
The State disclosed pediatric and forensic-interview experts (Dr. Dutton and Paula Samms) to testify about child sexual abuse disclosure patterns and interview protocols.
Reams notified the court he would call Dr. Deborah Davis to provide educational expert testimony about general causes of false reports in child sexual-abuse cases (intentional deception, memory distortion, guessing, compliance with suggestion), and said she would not opine on the facts of this case or J.L.’s credibility.
The State moved in limine to exclude Dr. Davis; the District Court granted the motion, concluding Dr. Davis did not satisfy the criteria of the Scheffelman exception for experts who directly comment on a victim’s credibility.
The jury convicted Reams; he appealed, arguing the court erred by applying Scheffelman to exclude Dr. Davis’s general, educational testimony and that exclusion violated his right to present a defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court erred by excluding defense expert Dr. Davis’s testimony about general causes of false reports in child sexual-abuse cases	The State argued Dr. Davis was unqualified to directly or indirectly undermine the victim’s credibility under the Scheffelman criteria and exclusion was proper; any error was harmless because similar points were elicited from State witnesses on cross	Reams argued Dr. Davis would give general, educational testimony outside jurors’ common experience and would not opine on J.L.’s credibility, so Scheffelman did not apply and the testimony should be admitted under M. R. Evid. 702	Court held the District Court erred: Scheffelman applies only to experts who directly comment on a victim’s credibility; educational testimony that only indirectly bears on credibility need not meet Scheffelman; exclusion was not harmless. Reversed and remanded for a new trial.

State v. Scheffelman, 250 Mont. 334 (1991) (establishes narrow exception allowing experts to directly comment on a child-victim’s credibility only if certain criteria are met)
State v. Robins, 369 Mont. 291 (2013) (clarifies Scheffelman exception applies only to testimony that directly comments on victim credibility; indirect credibility-related expert testimony need not meet Scheffelman)
State v. Morgan, 291 Mont. 347 (1998) (approves admission of general educational expert testimony about child sexual-abuse patterns that does not apply to the facts or directly assess credibility)
State v. Grimshaw, 401 Mont. 27 (2020) (disallows statistical testimony regarding false reporting in child sexual-abuse cases)
State v. Scott, 257 Mont. 454 (1993) (supports use of expert testimony to explain contradictory behavior of child abuse victims to assist jurors)