Julio Venalonzo, A/k/a Melvin Manzanares(z) v. the People of the State of Colorado

Summary

The court held that whether testimony is lay or expert depends on whether the opinion rests on ordinary experience or specialized knowledge, and it concluded that portions of a forensic interviewer's testimony improperly presented expert opinions as lay testimony. It also held that the interviewer and the victim's mother improperly bolstered the children's credibility, while the investigating officer's testimony was properly admitted because the defense opened the door. Because the improper testimony substantially affected the central credibility issue, the court reversed and remanded for further proceedings.