The Supreme Court of Florida held that "child sexual abuse accommodation syndrome" [hereinafter CSAAS] should not have been admitted without subjecting it to an evaluation under the Frye standard. The court conducted its own evaluation of the mental health counselor's expert testimony and concluded that CSAAS was not generally accepted by the scientific community, and therefore inadmissible.

The defendant was accused of three counts of sexual battery on a child under twelve by vaginal penetration with his finger. A mental health counselor testified, over the reliability-based objections of the defense, that the child exhibited symptoms and diagnostic criteria typically associated with sexually abused children. On appeal, the court held that syndrome evidence, such as CSAAS, and profile evidence share the same defect—neither has reached the level of general acceptance in the relevant scientific community. The court noted the writings of Dr. John Myers in reaching the conclusion that accommodation syndrome is not probative of abuse because the clinician reasons from the presence of sexual abuse to reactions of sexual abuse. (In contrast, battered child syndrome reasons from the type of injury to the cause of the injury.) The admission of CSAAS was erroneous and affected the verdict.