Is there any case law where a prosecutor made a statement that a child witness recanted due to leading questions?

The first alleged vouching, the prosecutor's statement that a child witness recanted due to leading questions, is not vouching. The prosecutor did not state that he believed the witness, he merely argued a reasonable inference from the facts. See United States v. Molina, 934 F.2d 1440, 1444-46 (9th Cir.1991). Additionally, the second allegation of vouching, the prosecutor's statement that he was able to "clear everything up on redirect" is not improper in the context in which it was presented. The prosecutor merely stated that the victim's responses on redirect clarified her testimony.

The prosecutor's statement that the victim had never met the defense attorney before cross-examination also was not vouching but it did refer to a matter that was not in evidence. There was no evidence presented at trial that the victim had not met the defense attorney prior to cross-examination. While the statement about the victim not having met the defense attorney was improper, it was harmless. The prosecutor made a lengthy closing argument and mentioned this statement only once in passing, and in the context of why the children may have been frightened by the proceedings and the cross-examination. Furthermore, the district court's instruction to the jury that the lawyers' statements were not evidence cured any error on the part of the prosecutor. See United States v. Baker, 10 F.3d 1374, 1416 (9th Cir.), cert. denied, 115 S.Ct. 330 (1994).