Illinois Appellate Court
Criminal Court
Hearsay
Defendant was convicted, after jury trial, of predatory criminal sexual assault of a child. State committed error by introducing unduly prejudicial out-of-court statements for the purported purpose of explaining the steps of an investigation. Court should have sua sponte conducted a Cameron hearing, to determine appropriate extent to which State could use potentially prejudicial evidence in its case. Nurse, who was allowed to testify as expert, should not have been allowed to offer opinion that child victim's complaints were credible, and prosecutor improperly commented that jury should defer to nurse in determining credibility of child's claims; and prosecutor improperly expressed his own personal opinion on child's credibility. (APPLETON and HOLDER WHITE, concurring.)