Carlisle v. State

Christopher Carlisle appeals his conviction for sexual battery on a child while in a position of familial or custodial authority. Carlisle argues the trial court improperly restricted his ability to cross-examine the victim regarding her recantation of previous sexual abuse allegations against Car-*481lisle. Because the trial court erred and the error was not harmless, we must reverse and remand for a new trial.

Facts

Carlisle and his wife adopted the victim and the victim’s younger brother when the children were very young. In 2005, when the victim was eleven, the victim told a therapist that…