Opinion
No. 423 WAL 2018
04-30-2019
COMMONWEALTH of Pennsylvania, Respondent v. Rod L. JONES, Jr., Petitioner
ORDER
PER CURIAM.
AND NOW, this 30th day of April, 2019, the Petition for Allowance of Appeal is GRANTED, LIMITED TO the issues set forth below. Allocatur is DENIED as to all remaining issues. The issues, slightly rephrased for clarity, are:
(1) Whether testimony from a detective about victim responses and behaviors, when based on that detective's training, experience, and specialized knowledge, constitutes expert testimony and whether permitting such testimony from a lay witness is inconsistent with the plain language of Pa.R.E. 701, Pa. R.E. 702, and Commonwealth v. Huggins, 68 A.3d 962 (Pa. Super. 2013)?
(2) Whether the General Assembly's enactment of 42 Pa.C.S. § 5920 (relating to expert testimony in certain criminal proceedings) legislatively overruled this Honorable Court's decision in Commonwealth v. Dunkle, 529 Pa. 168, 602 A.2d 830 (1992), which held that specific types of victim responses and behaviors are within the range of common experience, easily understood by lay people, and for which expert analysis is inappropriate?