State v. Frost

In State v. Frost, 6th Dist. Nos. L-06-1142 & L-06-1143, 2007 Ohio 3469, the Court discussed whether Detective Lester was qualified as an expert witness in child sexual abuse. Although, as appellant points out, the defense in that case stipulated to the detective's qualifications in the area of sexual assault and sexual abuse investigation, the Court determined that Detective Lester's testimony regarding the issues of re-victimization, conditioning, and delayed reporting in child sexual abuse cases was not plain error. Our determination was based on the fact that the detective possessed a degree of "specialized knowledge" in the area of child sexual abuse based on training and on-the-job experience which included 21 years as a police officer and six years investigating sex offenses. Id. at P 42.