In re Pers. Restraint of Phelps

*158¶ 1 This case involves the issue of whether a prosecutor's closing argument asserting a victim was "groomed" by the defendant, where testimony of grooming was disallowed during trial, constitutes flagrant and ill-intentioned misconduct requiring reversal. The Court of Appeals, Division Two, granted Todd Phelps's personal restraint petition (PRP) and reversed his convictions for third degree rape and sexual misconduct with a minor.1 The Court of Appeals held that expert *1144testimony is required if the State intends to rely on grooming to argue and prove its case. Thus, because the prosecutor did…