Robert Brian Hendrickson v. The State of Texas

Summary

The Texas Court of Appeals affirmed Robert Brian Hendrickson’s conviction for indecency with a child by sexual contact and his thirty-year sentence. The court held that the trial court did not abuse its discretion by admitting testimony from a counselor concerning the Child and Adolescent Trauma Screen, and it concluded that Hendrickson’s bolstering arguments were not preserved for appellate review.

Holdings

1. The trial court did not abuse its discretion by admitting Hodgdon's expert testimony because the record supported a finding that she had appropriate training and experience in administering and interpreting the Child and Adolescent Trauma Screen.
2. Hendrickson's appellate bolstering arguments were not preserved because they did not comport with the general bolstering and availability objection made at trial; the court therefore overruled the issue.

Questions Presented

1. Whether the trial court abused its discretion under Texas Rule of Evidence 702 by admitting Hodgdon's expert testimony despite an alleged lack of qualification, training, and experience to administer and interpret the Child and Adolescent Trauma Screen.
2. Whether Hendrickson preserved and established a claim that Hodgdon's testimony improperly bolstered I.H.'s testimony.

Disposition

affirmed