Keith Hoglund, Appellant (defendant Below) v. State of Indiana, Appellee (plaintiff Below)

Summary

The Indiana Supreme Court held that expert testimony stating or implying that a child sexual-abuse complainant was not prone to exaggerate, fantasize, or fabricate constituted impermissible vouching under Evidence Rule 704(b). The court expressly overruled the prior common-law rule permitting such indirect accreditation, but affirmed because the properly admitted evidence independently supported the convictions and the unobjected-to testimony was cumulative. No separate opinions were filed.