State v. Rhinehart

In State v. Rhinehart, 322 N.C. 53, 366 S.E.2d 429 (1988), two law enforcement officers testified that a child victim of a sexual assault had provided consistent information to each officer regarding his assault. On appeal, the defendant argued that it was error to allow the officers to provide lay opinions to establish that the victim's statements to each of the officers were consistent. The Supreme Court of North Carolina held that this testimony was "helpful to the determination of a fact in issue -- namely, the precise nature of the sexual offense perpetrated by defendant." Rhinehart, 322 N.C. at 57, 366 S.E.2d at 431.