Velazquez v. Com

In Velazquez v. Com., 35 Va. App. 189, 543 S.E.2d 631 (Va. App. 2001), the defendant was accused and convicted of raping a 15-year-old girl. On appeal, the defendant claimed the trial court erred in allowing a sexual assault nurse examiner to testify regarding the cause of the victim's injury. The Velazquez court identified the nurse's qualifications, which were quite similar to those of Nurse Harrell's, and specifically mentioned "additional training in crisis intervention, physical assessment, injury recognition, documentation, evidence collection, photography and injury assessment." 543 S.E.2d at 634-35. The Velazquez court held that based on the nurse's training and experience, the nurse had knowledge concerning matters beyond a lay person's common knowledge which would assist the jury in understanding the evidence. 543 S.E.2d at 635.