Arizona Supreme Court

State of Arizona, Appellee v. Martin David Salazar-Mercado, Appellant

May 29, 2014234 Ariz. 590

Summary

The court held that Arizona Rule of Evidence 702(d) does not bar a qualified expert from offering general, educative testimony that is not applied to the particular facts of the case. Such "cold" testimony remains admissible if it satisfies Rule 702(a)-(c) and is not excluded under Rule 403. Applying that rule, the court upheld admission of testimony concerning general behavioral characteristics associated with child sexual abuse and affirmed the convictions and sentences.