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Pennsylvania Consolidated Statutes

18 Pa. Cons. Stat. § 3105 (2026)

 Prompt complaint.

✓ current as of May 2026
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§ 3105.  Prompt complaint.

Prompt reporting to public authority is not required in a prosecution under this chapter: Provided, however, That nothing in this section shall be construed to prohibit a defendant from introducing evidence of the complainant's failure to promptly report the crime if such evidence would be admissible pursuant to the rules of evidence.

(May 18, 1976, P.L.120, No.53, eff. 30 days; Mar. 31, 1995, 1st Sp.Sess., P.L.985, No.10, eff. 60 days)

 

1995 Amendment.  Section 18 of Act 10, 1st Sp.Sess., provided that the amendment of section 3105 shall apply to offenses committed on or after the effective date of Act 10.

Notes of Decisions
Cited in 18 cases (5 in the last 5 years), 1976–2025 · leading case: Commonwealth v. Dillon, 925 A.2d 131 (Pa. 2007).
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Commonwealth v. Dillon, 925 A.2d 131 (Pa. 2007). · cites it 10× “A jury may consider evidence of a lack of prompt complaint in cases involving sexual offenses pursuant to 18 Pa.C.S. § 3105, which provides: Prompt reporting to public authority is not required in a prosecution under this chapter: Provided, however, That nothing in this section…”
Commonwealth v. Lane, 555 A.2d 1246 (Pa. 1989). · cites it 2× “18 Pa.C.S. § 3105 (amended 1976); see also Commonwealth v.”
In Re Lokuta, 964 A.2d 988 (Ct. Jud. Disc. Pa 2008). · cites it 2× “§ 3105 provides: Prompt reporting to public authority is not required in a prosecution under this chapter: Provided, however, that nothing in this section shall be construed to prohibit a defendant from introducing evidence of the complainant's failure to promptly report the…”
Commonwealth v. Mlinarich, 498 A.2d 395 (Pa. 1985). · cites it 2× “18 Pa.C.S. § 3105. Section 2 of the Act provided that The alleged victim need not resist the actor in prosecutions [for rape]: Provided, however, That nothing in this section shall be construed to prohibit a defendant from introducing evidence that the alleged victim consented…”
Commonwealth v. Buser, 419 A.2d 1233 (Pa. Super. Ct. 1980). · cites it 2× “18 Pa.C.S. § 3105. After the daughter had testified concerning the prior incidents, appellant moved to dismiss all charges concerning any act that had occurred prior to three months before the abuse was reported to police.”
Commonwealth v. Shade, 363 A.2d 1187 (Pa. Super. Ct. 1976). · cites it 4× “June 6, 1973; 18 Pa.C.S. § 3105. [4] In n. 1 of the lower court opinion, the circumstances surrounding the ultimate report of the crime to the authorities is explained: "Ironically, the incident came to the attention of the state police about February 23, 1975, when [the…”
Commonwealth v. Snoke, 580 A.2d 295 (Pa. 1990). “This principle has been codified in our crimes code at 18 Pa.C.S. § 3105. Section 3105 states: Prompt reporting to public authority is not required in a prosecution under this chapter: Provided, however, that nothing in this section shall be construed to prohibit a defendant…”
Fischer v. Commonwealth, 482 A.2d 1148 (Pa. Commw. Ct. 1984). “Section 3105 of the Crimes Code, 18 Pa. C. S. §3105. Also, the statute of limitations for rape and incest cases has been extended to five years.”
In Re Whittaker, 948 A.2d 279 (Ct. Jud. Disc. Pa 2008). “§ 3105 provides: Prompt reporting to public authority is not required in a prosecution under this chapter: Provided, however, that nothing in this section shall be construed to prohibit a defendant from introducing evidence of the complainant’s failure to promptly report the…”
Fischer v. Dep't of Pub. Welfare, 482 A.2d 1137 (Pa. Commw. Ct. 1984). “In this regard, it is interesting to *238 note that other enactments of onr state legislature are to the effect that “fresh complaint” is no longer a factor in prosecuting those accused, of rape, Section 3105 of the Crimes Code, 18 Pa. C. S. §3105, and that the statute of…”
Com. v. Martinez Morales, M. (Pa. Super. Ct. 2025). · cites it 2× “§ 3106, which provides in relevant part, “No instructions shall be given cautioning the jury to view the complainant’s testimony in any other way than that in which all complainants’ testimony is viewed.”
Com. v. Ennis, L. (Pa. Super. Ct. 2016). “4 18 Pa.C.S. § 3105. 5 Pa.R.E. 613. 6 42 Pa.”
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