May 3, 2018
from Greenville County Robin B. Stilwell, Circuit Court Judge
Appellate Case No. 2016-001933
Appellate Defender David Alexander and Appellate Defender
Lara M. Caudy, both of Columbia, for Petitioner.
Attorney General Alan McCrory Wilson, Senior Assistant Deputy
Attorney General Deborah R.J. Shupe, both of Columbia, and
Solicitor W. Walter Wilkins, III, of Greenville, for
OF CERTIORARI TO THE COURT OF APPEALS
Roy Lee Jones appeals his convictions for first-degree
criminal sexual conduct (CSC) with a minor, second-degree CSC
with a minor, and two counts of committing a lewd act on a
minor. The issues Jones raises on appeal all concern the
admission of testimony from an expert witness qualified in
child sexual abuse dynamics. The court of appeals affirmed
Jones's convictions. State v. Jones, 417 S.C.
319, 790 S.E.2d 17 (Ct. App. 2016). Finding no reversible
error, we affirm the court of appeals, but we take the
opportunity to clarify the proper inquiry for determining
whether a particular subject area falls outside the realm of
lay knowledge, thus requiring expert testimony.
was charged with numerous offenses for the ongoing sexual
abuse of his then-girlfriend's two daughters. Testifying
at trial, the older daughter (Daughter 1) stated the abuse
began sometime in 2003 as she was entering the tenth grade.
While Jones's behavior was initially limited to sexual
comments about her body, Daughter 1 stated it progressed to
groping and eventually to sexual intercourse. In total,
Daughter 1 estimated Jones sexually abused her over a hundred
times until it came to a halt in 2009 when Jones was
imprisoned for assault and battery of a high and aggravated
younger daughter (Daughter 2) testified Jones began molesting
her when she was around ten years old, also beginning as
touching and groping before escalating into forced sexual
intercourse. Daughter 2 claimed she told Mother about the
abuse, but Mother did not take any steps to stop it. When
called to testify, Mother admitted Daughter 2 told her about
the abuse, but explained she did not immediately notify the
authorities after learning of the allegations because she
feared they would take her children from her.
State then presented expert testimony from Shauna
Galloway-Williams, who was qualified as an expert in child
sexual abuse dynamics. Jones objected to the admission of
Galloway-Williams' testimony, arguing the basis for her
opinions was not reliable and that the subject matter of her
testimony was not beyond the ordinary knowledge of the jury.
After the State proffered Galloway-Williams' testimony,
the trial judge concluded the subject matter of her testimony
was not common knowledge and determined she established
sufficient reliability for her testimony. Thus qualified,
Galloway-Williams testified generally about delayed
disclosure in sexual abuse cases and the response of
nonoffending caregivers. Galloway-Williams did not reference
the victims in this case, and after being questioned on
cross-examination, stated she had never met with any of the
other witnesses, including the victims and Mother.
in his own defense, Jones denied ever sexually abusing the
victims and claimed the charges were brought against him in
retaliation after he caught Daughter 1 stealing money from
him. Jones was found guilty of first-degree CSC with a minor,
second-degree CSC with a minor, and two counts of lewd act
upon a child, and was sentenced to life without parole for
first- and second-degree CSC and fifteen years'
imprisonment for each count of lewd act. After his
convictions were affirmed by the court of appeals, Jones
petitioned this Court for certiorari.
the court of appeals err by holding the trial court did not
abuse its discretion when it qualified Galloway-Williams as
an expert in child sex abuse dynamics when the subject matter
of her testimony was well within the realm of lay knowledge,
was highly ...