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Monday, April 01, 2019

STATE OF NEW JERSEY VS. G.E.P.

The court consolidates these four appeals for the purpose of writing a single opinion because they all present the issue of whether State v. J.L.G., 234 N.J. 265, 272 (2018), should be applied retroactively to reverse defendants' convictions of child sexual assault where an expert in "Child Sexual Assault Accommodation Syndrome" (CSAAS) was permitted to testify at trial. We accord J.L.G. pipeline retroactivity and reverse, because, given the State's reliance on the credibility of the victims and the paucity of other supporting evidence, the admission of CSAAS expert testimony in these four cases calls into question the validity of the guilty verdicts.