State v. Braham

Howard Braham appeals from a conviction on one count of first degree child molestation. He argues that the trial court improperly admitted expert testimony about the "grooming process" (techniques that child molesters use to establish a relationship with the victim). We reverse.

I

For approximately 3 weeks in 1989, 3-year-old A.H. and her mother, Patricia H., lived with Patricia's sister, Terry, and Terry's husband, Howard Braham.

One evening, when Patricia tried to bring A.H. upstairs to bed, A.H. resisted, saying her "coleta" hurt. When Patricia asked why, A.H. told her "Uncle Craigie touched…