Earnest A. Richardson, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court reversed Richardson's convictions and remanded for a new trial because the forensic interviewer improperly vouched for the truthfulness of the children's statements and thereby committed plain and reversible error. The court held that an interviewer laying a foundation for a recorded out-of-court statement may authenticate the recording but may not explain interview techniques or offer opinions about a child's truthfulness. The court rejected Richardson's separate challenge to the absence of a limiting instruction, finding no abuse of discretion. No separate opinions were filed.