State of Utah, Plaintiff and Appellee v. Phillip Rimmasch, Defendant and Appellant

Summary

The court reversed Rimmasch's convictions because the trial court admitted expert testimony that directly vouched for the daughter's truthfulness and offered opinions that she had been abused based on an inadequately founded psychological profile and subjective credibility assessments. The court held that scientific expert evidence remains subject to a threshold inherent-reliability requirement under Utah Rule of Evidence 702, followed by ordinary helpfulness and unfair-prejudice analysis. The court concluded that the errors likely affected the bench-trial verdict and remanded for retrial. Justice Durham concurred, advocating a more detailed four-factor framework for psychological evidence and distinguishing direct credibility opinions from expert opinions that only indirectly bear on credibility.