## Facts

- J.L.G. was prosecuted for sexual offenses against “Bonnie,” his girlfriend’s minor daughter.
- Bonnie alleged that abuse occurred over roughly 18 months while she was a young teenager.
- Bonnie testified that J.L.G. threatened her with a gun and threatened harm to her and her family if she disclosed the abuse.
- Bonnie delayed reporting; she later recorded an incident on her phone and disclosed the abuse to her mother, leading to J.L.G.’s arrest.
- At trial, the defense attacked Bonnie’s credibility, emphasizing the delayed disclosure as inconsistent with genuine abuse.
- The State presented expert testimony describing Child Sexual Abuse Accommodation Syndrome (CSAAS) and its five behavioral categories to explain delayed and other “counterintuitive” behaviors.
- A jury convicted J.L.G.
- The Supreme Court of New Jersey remanded for an evidentiary hearing on whether CSAAS remains generally accepted as reliable; the remand record supported only the proposition that delayed disclosure commonly occurs.

## Issues

1. Whether CSAAS-based expert testimony remains sufficiently reliable and generally accepted to be admissible under New Jersey Rule of Evidence 702 and the general-acceptance standard.
2. If only part of CSAAS is admissible, what limitations apply to expert testimony offered to explain a child’s reporting behavior.
3. Whether admission of full-scope CSAAS testimony at J.L.G.’s trial was reversible error.

## Decision

- The Supreme Court of New Jersey held that CSAAS testimony is no longer admissible, except for a narrow form of expert testimony addressing delayed disclosure.
- The Court concluded that the CSAAS construct (other than delayed disclosure) lacks current general acceptance as reliable in the relevant scientific community.
- The Court ruled that the expert testimony at J.L.G.’s trial improperly presented the full CSAAS framework and created a substantial risk of bolstering the complainant’s credibility.
- The Court vacated the conviction and remanded for a new trial consistent with the limited admissibility of delayed-disclosure testimony.

## Legal Principles

- Scientific or technical expert testimony is admissible only if it is reliable, generally accepted in the relevant scientific community, and helpful to the jury under N.J.R.E. 702.
- CSAAS evidence is inadmissible as a general explanatory “syndrome” for child sexual-abuse behavior; it may be admitted only to address delayed disclosure, and only in a narrowly tailored manner.
- Even when delayed-disclosure testimony is admitted, it cannot be used diagnostically or as substantive proof that abuse occurred, and it must not function as vouching for the complainant’s credibility.
- Courts must consider the risk that “syndrome” testimony will be perceived by jurors as confirming truthfulness; where prejudice is substantial and the testimony exceeds permissible limits, the error is not harmless.

## Conclusion

The court sharply restricted behavioral expert testimony in child sexual-abuse prosecutions, permitting only limited expert evidence that delayed disclosure is a recognized phenomenon while excluding broader CSAAS testimony as unreliable and unduly prejudicial; because the jury heard the full CSAAS framework, the conviction was vacated and the matter was remanded for a new trial.


State v. J.L.G., 234 N.J. 265, 190 A.3d 442 (N.J. 2018)