State v. Lovern

Defendant appeals from a judgment of conviction for 16 counts of sexual abuse in the first degree. ORS 163.427. In his first two assignments of error, he argues that the trial court erred in admitting a medical doctor’s testimony regarding the “process of disclosure” and recantation by sexual abuse victims. His third assignment of error challenges the trial court’s admission of the doctor’s medical diagnosis that the complainant had been sexually abused. As explained below, we agree with defendant that the latter ruling was, in all events, “an error of law apparent on the face of the record,”…