State v. Miama Kromah
Kromah was convicted for (1) infliction of great bodily injury upon a child, and (2) unlawful neglect of a child. On appeal, Kromah claimed that the trial court erred in permitting two State’s witnesses to testify about hearsay conversations that they had with the child victim (the child did not testify at trial). One State’s witness, a “forensic interviewer” who interviewed the alleged child victim, testified regarding her “compelling finding” of physical abuse. The witness was also qualified as an expert witness. The Supreme Court said the admission of this testimony was error, and that the witness’ statements were equivalent to that witness stating that she believed the child victim.
Despite the admission of this erroneous testimony, the Supreme Court affirmed the result, citing the overwhelming evidence of guilt, and finding the trial court’s error harmless beyond a reasonable doubt.