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15 Washington opinions name it 1 courts 1979–2025 6 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Martinezgreen2 sentences2025The State concedes that the testimony was not admissible under the fact of complaint doctrine,4 but argues that Vilendre’s ineffective assistance of counsel claim fails 4 Under the fact of complaint doctrine, “the State may present evidence that the victim reported the sexual violence to someone as part of its case in chief.” State v. Ortiz Martinez, 196 Wn.2d 605, 611 , 476 P.3d 189 (2020). 2025But our Supreme Court recently rejected an attempt to abandon to the doctrine in Martinez, 196 Wn.2d at 614 (“Because the fact of complaint doctrine protects victims and provides an important supplement to the current rules of evidence, we decline to abandon the doctrine.”). | 1 | 5 |
State v. Fergusongreen2 sentences2020See, e.g., Ferguson, 100 Wn.2d at 144 .1 2. 2017State v. Ferguson, 100 Wn.2d 131, 135 , 667 P.2d 68 (1983)(citing State v. Goebel, 40 Wn.2d 18, 25 , 240 P.2d 251 (1952))."The rule admits only such evidence as will establish that the complaint was timely made." Id. | 1 | 4 |
State v. Murleygreen2 sentences2020The fact of complaint rule, a case law exception to the hearsay rule, derives from the antiquated doctrine of “hue and cry.” State v. Murley, 35 Wn.2d 233 , 236–37, 212 P.2d 801 (1949); State v. Chenoweth, 188 Wn. 2020The fact of complaint rule, a case law exception to the hearsay rule, derives from the antiquated doctrine of “hue and cry.” State v. Murley, 35 Wn.2d 233 , 236–37, 212 P.2d 801 (1949); State v. Chenoweth, 188 Wn. | 1 | 3 |
State v. Alexandergreen2 sentences2018Alexander, 64 Wn. 2018App. 477,481-82 , 953 P.2d 816 (1998)(child molestation case where the court upheld the admissibility of fact of complaint testimony from three witnesses). 9 State v. Alexander, 64 Wn. | 1 | 2 |
State v. Goebelgreen2 sentences2017State v. Ferguson, 100 Wn.2d 131, 135 , 667 P.2d 68 (1983)(citing State v. Goebel, 40 Wn.2d 18, 25 , 240 P.2d 251 (1952))."The rule admits only such evidence as will establish that the complaint was timely made." Id. 2017State v. Ferguson, 100 Wn.2d 131, 135 , 667 P.2d 68 (1983)(citing State v. Goebel, 40 Wn.2d 18, 25 , 240 P.2d 251 (1952))."The rule admits only such evidence as will establish that the complaint was timely made." Id. | 1 | 2 |
State v. Florczakgreen1 sentence1998See Florczak, 76 Wn. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. DeBolt
green
2 sentences2025For that reason, we do not address Combs’s argument that the doctrine should be abandoned. -3- No. 85277-9-I/ 4 App. 58, 63 , 808 P.2d 794 (1991). 2024App. 2d at 508). 6 No. 39057-8-III State v. Miller Miller argues that his defense counsel was ineffective for failing to object to the admission of prior statements made by KO to MG and TG under the fact-of-complaint doctrine.2 “The fact-of-complaint or ‘hue and cry’ doctrine is a case law exception to the hearsay rule allowing the State to introduce evidence in its case in chief that a rape victim has made a timely complaint.” State v. DeBolt, 61 Wn. | 3 | 1998–2025 |
State v. Chenoweth
green
2 sentences2025State v. Chenoweth, 188 Wn. 2020The fact of complaint rule, a case law exception to the hearsay rule, derives from the antiquated doctrine of “hue and cry.” State v. Murley, 35 Wn.2d 233 , 236–37, 212 P.2d 801 (1949); State v. Chenoweth, 188 Wn. | 3 | 2018–2025 |
State v. Ackerman
green
2 sentences2018But '[t]he rule admits only such evidence as will establish that the complaint was timely made.'"6 The rule excludes "evidence of 2 State v. Ackerman, 90 Wn. 2018App. at 63 (indecent liberties case, statements made to the victim's sister and social worker were both admitted under the fact of complaint doctrine); State v. Ackerman, 90 Wn. | 2 | 2014–2018 |
State v. Kelly
green
1 sentence2017State v. Kelly, 102 Wn.2d 188, 193 , 685 P.2d 564 (1984). 5 We reject the State's argument that a showing of timeliness is no longer required under the fact of complaint rule. | 1 | 2017–2017 |
State v. Cissne
green
1 sentence2017State v. Kelly, 102 Wn.2d 188, 193 , 685 P.2d 564 (1984). 5 We reject the State's argument that a showing of timeliness is no longer required under the fact of complaint rule. | 1 | 2017–2017 |
White v. Illinois
green
1 sentence1998But if her hearsay statements bear adequate indicia of reliability, they are admissible notwithstanding her availability as a witness. 2 White, 502 U.S. at 353-54 . | 1 | 1998–1998 |
Miranda v. Heirs of Erazo
green
1 sentence1979The fact of complaint rule, first announced in State v. Hunter, 18 Wash. 670 , 52 P. 247 (1898), provides that the prosecution in a forcible rape case may present evidence of the fact of the victim's complaint in its case in chief. | 1 | 1979–1979 |
State v. Hunter
green
1 sentence1979The fact of complaint rule, first announced in State v. Hunter, 18 Wash. 670 , 52 P. 247 (1898), provides that the prosecution in a forcible rape case may present evidence of the fact of the victim's complaint in its case in chief. | 1 | 1979–1979 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.