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Appeals court reviews limits on expert testimony and prior‑bad‑act evidence in Martinez appeal
Summary
In the Martinez appeal, counsel argued that testimony about why a school complaint occurred and expert delayed‑disclosure testimony were wrongly admitted or excluded, and that struck prior‑bad‑act lines prejudiced the defense; the Commonwealth defended the trial court's discretion.
May it please the court. In Commonwealth v. Martinez, defense counsel Megan Siddle told the panel the trial court improperly curtailed cross‑examination about why the complainant received attention at school and permitted expert testimony by Dr. Block that improperly bolstered the complainant's credibility.
Siddle said the defense sought to place the first complaint in context so the jury could evaluate motive and credibility, and that expert testimony about delayed disclosure was unnecessary because the disclosure timeline (two days vs. nine days) was within jurors’ common experience. She argued the single line of vivid prior‑bad‑act testimony — later struck — nevertheless prejudiced the jury and that a new trial is warranted.
Commonwealth ADA Charlie Marshall told the court the trial judge acted well within discretion under an abuse‑of‑discretion standard. He said the record contained a range of impeachment material about the complainant, that the guidance counselor (first complaint witness) and other evidence were before the jury, and that Dr. Block has routinely offered admissible expert context on delay in disclosure. He also noted the jury received limiting instructions and pointed to other evidence addressing credibility.
The panel questioned how much delay must exist before expert insight is needed, whether jurors can assess delay without expert help, and whether an isolated, struck statement can produce ineradicable prejudice, especially where other limiting instructions were given. The court took the arguments under advisement.
