People v. Adoms

The court properly exercised its discretion in permitting expert testimony relating to child sexual abuse syndrome (CSAS). The expert’s testimony provided a possible explanation, beyond the knowledge of the average juror, for the victim’s delay in reporting repeated instances of sexual abuse occurring over a long period of time (see People v Carroll, 95 NY2d 375, 387 [2000]; People v Gilley, 4 AD3d 127, 128 [2004], lv denied 2 NY3d 799 [2004]). Regardless of whether defendant expressly raised the issue of delayed disclosure, the jury may have been concerned that the delay impacted the…