The "grooming" of children for sexual molestation is a legitimate subject of expert testimony. The legitimacy of grooming as a subject of expert testimony is established sufficiently to be judicially noticed. Grooming is a subject matter that falls in the study of the behavior of offenders who sexually victimize children, a legitimate field of expertise. Although social awareness of child sexual abuse has increased, expert testimony on grooming is still useful to the jury because not all jurors are aware of the concept or have the depth of understanding to resolve the issues before them.
Morris v. State