Missouri Court of Appeals, Southern District / May 23, 2023
STATE OF MISSOURI, Plaintiff-Respondent v. JERRY R. YOAKUM, Defendant-Appellant
Jerry R. Yoakum appealed his convictions for child molestation and sexual misconduct, arguing the circuit court erred by not allowing his expert witness to testify about flaws in the forensic interview techniques used with the victim. The appellate court affirmed the convictions. It held that Yoakum failed to preserve the claim for appellate review because he did not make an offer of proof at trial regarding the expert's excluded testimony. The court also declined to exercise its discretion to conduct plain-error review.