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Mullis v. State, 292 Ga.App. 218, 664 S.E.2d 271 (June 25, 2008). 1. Trial court properly allowed testimony of psychologist “about the effects of child abuse on the subjects of that abuse … based on tests developed either in the scientific community or from his own clinical experience.” 2. Trial court properly allowed “the psychologist to testify that the victim’s symptoms and accounts were ‘ highly consistent’ with sexual abuse.” 3. Trial court properly allowed psychologist to testify “that a person with the [child abuse] victim’s level of intelligence would have difficulty fabricating a detailed fictional account of abuse. The psychologist explained that the victim had a composite IQ score of 74, merely 5 points above what is considered mentally retarded. … Because the trial court was authorized to conclude that one’s ability to manufacture stories of abuse based upon his or her IQ level fell beyond the ken of the average juror, the challenged testimony was admissible. See In re: B.H., 190 Ga.App. 131, 133-134(3) (378 S.E.2d 175) (1989) (allowing opinion testimony that a child of the victim’s age would have difficulty making up a story of abuse).” Osborne v. State, 291 Ga.App. 711, 662 S.E.2d 792 (May 29, 2008). At defendant’s trial for rape and child molestation, over defendant’s objection, trial court properly allowed State’s expert “to testify that the child’s manner of responding during the interview showed signs of spontaneity and detail that were not consistent with being coached. Because this testimony did not impermissibly address the ultimate issue before the jury or bolster the child’s credibility, we find no error.” Child here responded to questions about molestation ‘in a singsong manner;’ defense suggested this was a result of coaching. Accord, Stillwell v. State , 294 Ga.App. 805, 670 S.E.2d 452 (November 6, 2008); McCowan v. State , 302 Ga.App. 555, 691 S.E.2d 360 (March 1, 2010); Conley v. State , 329 Ga.App. 96, 763 S.E.2d 881 (September 22, 2014). Hafez v. State, 290 Ga.App. 800, 660 S.E.2d 787 (March 21, 2008). Trial court properly allowed social worker’s testimony “that she was treating the victim for ‘exhibiting intrusive thoughts and memories of abuse that are triggered by current events in his life.’ The transcript shows that the trial court instructed the witness to testify only about the victim’s symptoms and her treatment of the victim and further instructed her not to give any testimony concerning any diagnosis she had made; the prosecuting attorney also made clear to the witness that she could not testify that the victim had been abused. … Unlike the cases defendants rely on, the expert witness in this case did not express an opinion that the victim in fact had been abused or comment or opine that she believed his memories of abuse accurately reflected real events. Rather, we find the expert’s testimony in this case to be more akin to that of the expert witnesses in cases such as Odom v. State, 243 Ga.App. 227, 228-230(1)(a), (b) and (d) (531 S.E.2d 207) (2000), and Cooper v. State, 200 Ga.App. 560(2) (408 S.E.2d 797) (1991) [fn: In Cooper, the expert testified the victim suffered from child abuse syndrome. Cooper, 200 Ga.App. at 560(2). In Odom, we found witnesses were properly allowed to testify that the victim had been referred for treatment of ‘alleged’ child abuse and that the child's physical exam and related behavior were consistent with sexual abuse, but that it was impermissible for another expert to testify concerning his opinion that the child had been sexually abused. Odom, 243 Ga.App. at 228-230. ], and similar cases in which we held that the experts’ testimony was not the expression of an opinion or conclusion that the victim had in fact been abused and did not comment impermissibly on the victim’s credibility. The trial court did not err by denying the motion for new trial on this basis.” Cooper v State, 287 Ga.App. 901, 652 S.E.2d 909 (October 23, 2007). No improper bolstering where doctor and “forensic interviewer” testified that child told them she had been molested by defendant. “Nevertheless, we note that neither expert improperly expressed her opinion as to an ultimate fact within the ken of the jurors, see, e.g., Allison v. State, 256 Ga. 851, 853(5) (353 S.E.2d 805) (1987); rather, each expert merely recounted what [victim] told her.” Harris v. State, 283 Ga.App. 374, 641 S.E.2d 619 (February 1, 2007). 1. At defendant’s rape trial, State presented testimony from a clinical psychologist on the subject of “ common patterns of behavior exhibited by rape victims .” “Harris contends that such testimony improperly bolstered the credibility of the victim and invaded the province of the jury. We are unpersuaded. Under Georgia law, an expert witness may testify ‘as to the existence of certain typical patterns of behavior exhibited by victims of rape,’ as long as the jury was permitted to draw for itself the final conclusion as to whether the victim in the case at hand was raped, as was the case here. Edmonson v. State, 212 Ga.App. 449, 450-451(1) (442 S.E.2d 300) (1994), overruled in part on other grounds, Curtis v. State, 275 Ga. 576, 578(1) (571 S.E.2d 376) (2002). Accord Odom [ v. State, 243 Ga.App. 227, 229(1)(b) (531 S.E.2d 207) (2000)] (expert testimony that child’s behavior following alleged molestation was consistent with sexual abuse was admissible); Hall v. State, 201 Ga.App. 626, 626-627(2) (411 S.E.2d 777) (1991) (same). Such testimony does ‘not amount to an expert opinion as to whether the victim had been raped.’ Edmonson, 212 Ga.App. at 451(1).” Accord, Harris v. State , 330 Ga.App. 267, 765 S.E.2d 369 (September 23, 2014). 2. Other testimony by the psychologist was improperly admitted, however, namely, “testimony from a clinical psychologist opining that it is a common misconception that people will make up rape allegations for the purpose of revenge. We agree that the testimony was improper but find that it did not
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