State v. Solether

In State v. Solether, 6th Dist. No. WD-07-053, 2008 Ohio 4738, the Court held that an officer who testified about delayed reporting, and whose testimony was based largely upon his personal experience, was qualified as an expert. The Court reached this conclusion upon determining that the fact that delayed reporting by sexual assault victims is not uncommon is not within the knowledge of the average juror. Id. at P 65. Accordingly, the Court found that the officer's testimony required "specialized knowledge" and was properly categorized as expert testimony.