State v. Jones, 817 S.E.2d 268

Roy Lee Jones was convicted of first- and second-degree criminal sexual conduct and two counts of lewd acts for ongoing sexual abuse of his girlfriend’s two daughters; sentenced to life without parole for the CSC convictions and additional terms for lewd acts.
Victims testified to long‑running abuse beginning when they were minors; mother acknowledged being told but delayed reporting due to fear of losing her children.
State called Shauna Galloway‑Williams as an expert in “child sexual abuse dynamics” to testify generally about delayed disclosure by victims and nonoffending caregiver responses; she did not interview or evaluate the victims.
Jones objected, arguing (1) the subject matter was within lay knowledge (the State had effectively proffered a forensic interviewer rather than a distinct expert) and (2) the testimony lacked demonstrated reliability or peer‑reviewed support and improperly bolstered victims’ credibility.
Trial court admitted the testimony after finding the topics fell outside ordinary juror knowledge and that the expert’s methods were sufficiently reliable; the Court of Appeals affirmed; the Supreme Court granted certiorari and affirmed as modified, clarifying the proper inquiry for whether a subject is beyond lay knowledge.

Issue	Plaintiff's Argument (Jones)	Defendant's Argument (State)	Held
Whether testimony on delayed disclosure and nonoffending caregiver behavior was outside lay knowledge and therefore required expert testimony	Topic was within ordinary juror knowledge; labeling it "child sex abuse dynamics" masked a forensic interviewer role	Testimony explains behavioral dynamics unfamiliar to jurors and will assist the trier of fact	Court held delayed disclosure is a recognized specialized area; nonoffending caregiver behavior may be admissible; trial judge did not abuse discretion admitting testimony; reversed part of court of appeals to the extent it relied on voir dire to evaluate need for expert testimony
Whether the expert's testimony was reliable (gatekeeping under Rule 702)	Expert failed to cite studies or demonstrate individual reliability and thus the testimony should have been excluded	Expert testified her opinions were supported by peer‑reviewed literature and accepted by professionals; she could supply citations and participates in peer review	Court held the trial judge satisfied the threshold reliability inquiry for nonscientific testimony; admission was not an abuse of discretion

State v. Cope, 405 S.C. 317 (discretionary review of expert testimony admissibility)
State v. Council, 335 S.C. 1 (Rule 702 framework for expert admissibility)
Watson v. Ford Motor Co., 389 S.C. 434 (expert testimony for subjects outside ordinary lay knowledge)
State v. Anderson, 413 S.C. 212 (recognizing experts may testify to behavioral characteristics of sex‑abuse victims)
State v. Chavis, 412 S.C. 101 (requiring evidence of individual expert reliability for forensic interviewer testimony)
State v. Kromah, 401 S.C. 340 (limits on forensic interviewer testifying to victim veracity)
State v. White, 382 S.C. 265 (no formulaic approach to reliability for nonscientific expert testimony)
State v. Collins, 409 S.C. 524 (trial court deference in Rule 403 prejudice/probative balancing)
Mu’Min v. Virginia, 500 U.S. 415 (purpose and limits of voir dire)
Rosales‑Lopez v. United States, 451 U.S. 182 (voir dire’s role in jury impartiality)