State v. Davis, 239 N.C. App. 522 (Mar. 3, 2015)

modified and affirmed on other grounds, 368 N.C. 794 (Apr. 15, 2016)

In this child sexual abuse case, the State’s treating medical experts did not vouch for the victim’s credibility. The court noted that defendant’s argument appears to be based primarily on the fact that the experts testified about the problems reported by the victim without qualifying each reported symptom or past experience with a legalistic term such as “alleged” or “unproven.” The court stated: “Defendant does not cite any authority for the proposition that a witness who testifies to what another witness reports is considered to be ‘vouching’ for that person’s credibility unless each disclosure by the witness includes a qualifier such as ‘alleged.’ We decline to impose such a requirement.”