☢ test - Í

Reversal required because victim’s reports were “the primary evidence that the crimes occurred. … There was no physical evidence corroborating R.C.'s various accounts.” Also important that defendant denied touching victim, and that trial court refused to give curative instruction. Distinguished, Alford (February 5, 2013), above. Lewis v. State, 317 Ga.App. 218, 735 S.E.2d 1 (June 18, 2012). Convictions for family violence aggravated assault and battery affirmed; trial court erred, but harmless, in allowing detective to testify “that it was common for victims of domestic violence to change their stories about being abused. … Lewis argues that ‘the obvious purpose of this testimony was to suggest to the jury that [the victim's] sworn testimony in the courtroom was a lie,’ and an improper comment on whether the victim was telling the truth. We agree. While an expert qualified to testify as an expert in the field of the cycle of domestic violence may be qualified to testify that in such cases, ‘a victim often will go into denial, minimize the violence which has occurred, and become reluctant to prosecute her partner,’ Hawks v. State, 223 Ga.App. 890, 893(4) (479 S.E.2d 186) (1996), this witness was not so qualified. ‘The fact that, in the officer's previous experience, it was not uncommon for domestic violence victims to recant their stories was not relevant to explain either the conduct or the testimony of the victim[ ] in the instant case.’ (Citation and punctation omitted.) Howie v. State, 281 Ga.App. 730, 732 (637 S.E.2d 134) (2006). Nonetheless, considering the facts of this case and the evidence as a whole, including the testimony of the two similar transaction witnesses who apparently recanted or minimized their initial complaints against Lewis for striking them, we find it highly improbable that the challenged testimony contributed to the verdict.” Twiggs v. State, 315 Ga.App. 191, 726 S.E.2d 680 (March 27, 2012). Aggravated child molestation and related convictions affirmed; no improper bolstering where prosecutor asked detective if victim was “forthcoming” during her forensic interview. “[T]he question appears to have been directed at determining whether the victim provided information that led to further investigation, not at determining whether McCoy believed the victim was telling the truth. At most, [Detective] McCoy's testimony addressed how the victim delivered the information, and thus it ‘addressed only [McCoy's] objective observations of [the victim's] behavior, not whether she found [the victim's] statements believable or credible.’ (Citation and punctuation omitted.) Damerow v. State, 310 Ga.App. 530, 537(4)(a)(ii) (714 S.E.2d 82) (2011).” Distinguishing Brown v. State, 260 Ga.App. 77 (579 S.E.2d 87) (2003) (witness testified that victim was “forthcoming” when asked to describe her honesty). Handley v. State, 289 Ga. 786, 716 S.E.2d 176 (October 3, 2011). Malice murder conviction affirmed; no improper bolstering where State’s witness was allowed to express his desire to better his life by telling the truth at trial. “[W]e question whether a witness can be prohibited on direct examination from asserting his own credibility by testifying that he is telling the truth and giving some explanation. Compare Manzano v. State, 282 Ga. 557, 560(3)(b) (651 S.E.2d 661) (2007); Hardy v. State, 293 Ga.App. 265, 269(4) (666 S.E.2d 730) (2008).” Strickland v. State, 311 Ga.App. 400, 715 S.E.2d 798 (August 16, 2011). Child molestation and related convictions affirmed; detective’s testimony didn’t amount to improper bolstering. Detective testified that she terminated interview with witness after she “ascertained that a molestation incident occurred” so that she could call in the Georgia Center for Child Advocacy to conduct “a nonbias interview.” “[Detective] Aviles's testimony did not speak to B.S.'s credibility, but only to Aviles's reasons for ending the interview at that time. Her testimony was ‘not a clear comment on [B.S.]'s credibility as to [her] allegations of molestation,’ [ Branesky v. State, 262 Ga.App. 33, 36(3)(a) (584 S.E.2d 669) (2003)] and counsel's failure to object did not indicate deficient performance.” Westbrooks v. State, 309 Ga.App. 398, 710 S.E.2d 594 (April 21, 2011). Convictions for child molestation and aggravated child molestation affirmed; no improper bolstering of child victim’s credibility when forensic interviewer explained “why it was normal for children not to provide full disclosure during a forensic interview.” Testimony at issue: “They’re – just met somebody they’ve never met before and now you’re talking about all this stuff. Kids tend to think they cause things. They tend to think they’ll be in trouble if they talk about things. There’s all kind of reasons that children tell or don’t tell. …” This testimony “was relevant and did not directly address S.W.’s credibility or express a direct opinion that S.W. had been sexually abused. Moreover, ‘the fact that such testimony may also indirectly, though necessarily, involve a child’s credibility does not render it inadmissible.’ Mullis v. State , 292 Ga.App. 218, 220(3)(b), 664 S.E.2d 271 (2008) (citation and punctuation omitted); see Howell v. State , 278 Ga.App. 634, 643(8), 629 S.E.2d 398 (2006) (same); Odom v. State , 243 Ga.App. 227, 229(1)(a), 531 S.E.2d 207 (2007) (same). As such, the forensic interviewer’s testimony did not improperly bolster S.W.’s testimony or address the ultimate issue before the jury.” Howell overruled on other grounds, Hatley v. State , 290 Ga. 480, 722 S.E.2d 67 (February 6, 2012). Accord, Thomas (November 28, 2012), above.