Schutz v. State
The appellant was convicted of aggravated sexual assault of his six-year-old daughter. The conviction was affirmed by the Court of Appeals, but the appellant petitioned for discretionary review, arguing the trial court erroneously admitted expert testimony regarding the child complainant's credibility concerning manipulation and fantasy. The Texas Court of Criminal Appeals reversed the judgment, holding that such expert testimony constitutes an impermissible direct comment on the truthfulness of specific allegations, thereby invading the province of the jury. The court distinguished between admissible general testimony on a witness's capacity/disposition for truthfulness and inadmissible expert conclusions on specific allegations.