State v. O'hanlan

In State v. O'Hanlan, 153 N.C. App. 546, 562, 570 S.E.2d 751, 761 (2002), a law enforcement officer testified that he had not extensively investigated some physical evidence because the victim of the sexual assault was able to positively identify her attacker. On appeal to this Court, the defendant argued that the officer's testimony constituted expert testimony that served to bolster the credibility of the complaining witness. The Court disagreed. The Court held that the officer was not offering his opinion that the victim had, in fact, been assaulted, but was explaining why he had not pursued more scientific testing of the physical evidence. The Court held that the officer's testimony was "helpful to the fact-finder in presenting a clear understanding of his investigative process." O'Hanlan, 153 N.C. App. at 563, 570 S.E.2d at 762.