9 Connecticut opinions name it 2 courts 1996–2021 1 in the last five years
The cases below were cited by Connecticut 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. De Wolfgreen2 sentences2016We further explained that, following its adoption by this court in State v. DeWolf, 8 Conn. 93, 100 (1830), the fresh complaint doctrine applied for forty-six years until it was modified in State v. Kinney, 44 Conn. 153 (1876). 2016We further explained that, following its adoption by this court in State v. DeWolf, 8 Conn. 93 , 100 (1830), the fresh complaint doctrine applied for forty-six years until it was modified in State v. Kinney, 44 Conn. 153 (1876). | 5 | 5 |
People v. Browngreen2 sentences1996In People v. Brown, 8 Cal. 4th 746 , 883 P.2d 949 , 35 Cal. Rptr. 2d 407 (1994), the California Supreme Court abolished the fresh complaint rule entirely. 1996In People v. Brown, 8 Cal. 4th 746 , 883 P.2d 949 , 35 Cal. Rptr. 2d 407 (1994), the California Supreme Court abolished the fresh complaint rule entirely. | 2 | 2 |
State v. Troupegreen2 sentences2016In Troupe , we explained that the doctrine "traces its roots to the fresh complaint rule"; (internal quotation marks omitted) State v. Troupe, supra, 237 Conn. at 294 , 677 A.2d 917 ; "[t]he narrow purpose of [which] ... was to negate any inference that because the victim had failed to tell anyone that she had been [sexually assaulted], her later assertion of [sexual assault] could not be believed." (Internal quotation marks omitted.) Id., at 296 , 677 A.2d 917 . 2016In Troupe , we explained that the doctrine "traces its roots to the fresh complaint rule"; (internal quotation marks omitted) State v. Troupe, supra, 237 Conn. at 294 , 677 A.2d 917 ; "[t]he narrow purpose of [which] ... was to negate any inference that because the victim had failed to tell anyone that she had been [sexually assaulted], her later assertion of [sexual assault] could not be believed." (Internal quotation marks omitted.) Id., at 296 , 677 A.2d 917 . | 1 | 3 |
Commonwealth v. Avilesgreen2 sentences2016See State v. Krieger, 803 A.2d 1026, 1031 (Me. 2002) (discussing application of first complaint rule in Maine, under which, unlike in Massachu- setts, ‘‘[n]either the details of the complaint . . . nor the identity of the perpetrator . . . [is] admissible’’); see also State v. Calor, 585 A.2d 1385, 1387 (Me. 1991) (noting that details of complaint are not admissible under doctrine). 17 In Commonwealth v. Aviles, 461 Mass. 60 , 71–73, 958 N.E.2d 37 (2011), the Supreme Judicial Court of Massachusetts reaffirmed the continuing vitality of the first complaint doctrine but changed the standard empl 2016See State v. Krieger, 803 A.2d 1026, 1031 (Me. 2002) (discussing application of first complaint rule in Maine, under which, unlike in Massachu- setts, ‘‘[n]either the details of the complaint . . . nor the identity of the perpetrator . . . [is] admissible’’); see also State v. Calor, 585 A.2d 1385, 1387 (Me. 1991) (noting that details of complaint are not admissible under doctrine). 17 In Commonwealth v. Aviles, 461 Mass. 60 , 71–73, 958 N.E.2d 37 (2011), the Supreme Judicial Court of Massachusetts reaffirmed the continuing vitality of the first complaint doctrine but changed the standard empl | 1 | 1 |
State v. Calorgreen1 sentence2016See State v. Krieger, 803 A.2d 1026, 1031 (Me. 2002) (discussing application of first complaint rule in Maine, under which, unlike in Massachu- setts, ‘‘[n]either the details of the complaint . . . nor the identity of the perpetrator . . . [is] admissible’’); see also State v. Calor, 585 A.2d 1385, 1387 (Me. 1991) (noting that details of complaint are not admissible under doctrine). 17 In Commonwealth v. Aviles, 461 Mass. 60 , 71–73, 958 N.E.2d 37 (2011), the Supreme Judicial Court of Massachusetts reaffirmed the continuing vitality of the first complaint doctrine but changed the standard empl | 1 | 1 |
State v. Kriegergreen1 sentence2016See State v. Krieger, 803 A.2d 1026, 1031 (Me. 2002) (discussing application of first complaint rule in Maine, under which, unlike in Massachu- setts, ‘‘[n]either the details of the complaint . . . nor the identity of the perpetrator . . . [is] admissible’’); see also State v. Calor, 585 A.2d 1385, 1387 (Me. 1991) (noting that details of complaint are not admissible under doctrine). 17 In Commonwealth v. Aviles, 461 Mass. 60 , 71–73, 958 N.E.2d 37 (2011), the Supreme Judicial Court of Massachusetts reaffirmed the continuing vitality of the first complaint doctrine but changed the standard empl | 1 | 1 |
State v. Madigangreen2 sentences2016The Vermont court based its decision in part on its view that most jurisdictions no longer recognize the fresh complaint doctrine; id., 528 ; which the court characterized as a ‘‘historic artifact’’; (internal quotation marks omitted) id., 529 ; but ‘‘sensibly prefer to apply the same rules of evidence in [sexual abuse] cases as in other cases.’’15 Id. 2016The Vermont court based its decision in part on its view that most jurisdictions no longer recognize the fresh complaint doctrine; id., 528 ; which the court characterized as a ‘‘historic artifact’’; (internal quotation marks omitted) id., 529 ; but ‘‘sensibly prefer to apply the same rules of evidence in [sexual abuse] cases as in other cases.’’15 Id. | 1 | 1 |
State v. Madigangreen1 sentence2016See State v. Madigan, 199 Vt. 211 , 122 A.3d 517 , 528-30 (2015) (rejecting fresh complaint rule as independent evidentiary doctrine on ground that it has become largely supplanted by ordinary rules of evidence, including rules on admission of prior consistent statements to rebut charges of recent fabrication, evidence to establish timing or circumstances of official report, excited utterances, statements made for purposes of medical diagnosis or treatment, and out-of-court statements by children under thirteen years of age or who are putative victims of abuse, neglect, or certain sexual crime | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Kinney
green
2 sentences2016We further explained that, following its adoption by this court in State v. DeWolf, 8 Conn. 93, 100 (1830), the fresh complaint doctrine applied for forty-six years until it was modified in State v. Kinney, 44 Conn. 153 (1876). 2016We further explained that, following its adoption by this court in State v. DeWolf, 8 Conn. 93 , 100 (1830), the fresh complaint doctrine applied for forty-six years until it was modified in State v. Kinney, 44 Conn. 153 (1876). | 3 | 1996–2016 |
State v. Daniel W. E.
green
2 sentences2021E., 322 Conn. 593 , 618–19, 142 A.3d 265 (2016)], permits the victim in a sexual assault case . . . to testify on direct examination regarding the facts of the sexual assault and the identity of the person or persons to whom the incident was reported. . . . 2021E., 322 Conn. 593 , 618–19, 142 A.3d 265 (2016)], permits the victim in a sexual assault case . . . to testify on direct examination regarding the facts of the sexual assault and the identity of the person or persons to whom the incident was reported. . . . | 2 | 2020–2021 |
State v. McKenzie-Adams
green
2 sentences2007The fresh complaint doctrine thus constituted a rare exception to the common-law rule that prohibited rehabilitative evidence in the absence of an attack on the witness’s credibility.” (Citations omitted; internal quotation marks omitted.) State v. McKenzie-Adams, 281 Conn. 486, 539 , 915 A.2d 822 (2007). 2007The fresh complaint doctrine thus constituted a rare exception to the common-law rule that prohibited rehabilitative evidence in the absence of an attack on the witness’s credibility.” (Citations omitted; internal quotation marks omitted.) State v. McKenzie-Adams, 281 Conn. 486, 539 , 915 A.2d 822 (2007). | 1 | 2007–2007 |
State v. Hill
green
1 sentence1996See, e.g., People v. Brown, 8 Cal. 4th 746 , 883 P.2d 949 , 35 Cal. Rptr. 2d 407 (1994); Battle v. United States, 630 A.2d 211 (D.C. 1993); State v. Hill, supra, 121 N.J. 150 . | 1 | 1996–1996 |
Battle v. United States
green
1 sentence1996See, e.g., People v. Brown, 8 Cal. 4th 746 , 883 P.2d 949 , 35 Cal. Rptr. 2d 407 (1994); Battle v. United States, 630 A.2d 211 (D.C. 1993); State v. Hill, supra, 121 N.J. 150 . | 1 | 1996–1996 |
People v. McDaniel
green
2 sentences1996The fresh-complaint rule responds to those jurors on their own terms.” State v. Hill, supra, 164 ; People v. McDaniel, 81 N.Y.2d 10, 17 , 611 N.E.2d 265 , 595 N.Y.S.2d 364 (1993); see State v. Kendricks, supra, 604 (“until the ‘presumption’ that the victim’s testimony is a fabrication disappears, we must retain the doctrine of ‘fresh complaint’ ”). 1996The fresh-complaint rule responds to those jurors on their own terms.” State v. Hill, supra, 164 ; People v. McDaniel, 81 N.Y.2d 10, 17 , 611 N.E.2d 265 , 595 N.Y.S.2d 364 (1993); see State v. Kendricks, supra, 604 (“until the ‘presumption’ that the victim’s testimony is a fabrication disappears, we must retain the doctrine of ‘fresh complaint’ ”). | 1 | 1996–1996 |
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.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.