§ 3106. Testimony of complainants.
The credibility of a complainant of an offense under this chapter shall be determined
by the same standard as is the credibility of a complainant of any other crime. The
testimony of a complainant need not be corroborated in prosecutions under this chapter.
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.
(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 3106 shall
apply to offenses committed on or after the effective date of Act 10.
Prior Provisions. Former section 3106, which related to the same subject matter, was added December
6, 1972 (P.L.1482, No.334), and repealed November 21, 1973 (P.L.339, No.115), effective
in 60 days.
Notes of Decisions
Cited in
37
cases (
20 in the last 5 years), 1981–2026 · leading case:
Commonwealth v. Johnson, 180 A.3d 474 (Pa. Super. Ct. 2018).
Commonwealth v. Johnson, 180 A.3d 474 (Pa. Super. Ct. 2018).
· cites it 2× “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.”
Commonwealth v. Mlinarich, 498 A.2d 395 (Pa. 1985).
· cites it 4× “, no instructions shall be given cautioning the jury to view the alleged victim's testimony in any other way than that in which all victims' testimony is viewed.”
Com. v. Walker, H., 305 A.3d 12 (Pa. Super. Ct. 2023).
· cites it 2× “18 Pa.C.S. § 3106. -5- J-S22020-23 The Commonwealth had a proper purpose for asking the voir dire question.”
Commonwealth v. Owens, 649 A.2d 129 (Pa. Super. Ct. 1994).
“18 Pa.C.S. § 3106; Commonwealth v. Cody, 401 Pa.”
Hardin v. State, 840 A.2d 1217 (Del. 2003).
“18 Pa. Cons.Stat. Ann. § 3106 (Purdon 1983) (prohibiting special scrutiny of victim’s testimony).”
Commonwealth v. King, 429 A.2d 1121 (Pa. Super. Ct. 1981).
“See Crimes Code, 18 Pa.C.S. § 3106 (1980 Supp.). According to the prosecutrix, after appellant picked her up in Lancaster, he drove her to his residence, locked her in the house, assaulted her, threatened her with a knife, removed her clothes, and had forcible intercourse with.”
Commonwealth v. Dickerson, 2 Pa. D. & C.4th 297 (1989).
“18 Pa.C.S. §3106. . 18 Pa.C.S. §3107. . We also note that both the victim and defendant testified at trial.”
Commonwealth v. Walker, H., Aplt. (Pa. 2025).
· cites it 5× “13B,9 the note to which specifically indicates that the jury instruction is consistent with the language of 18 Pa.C.S. § 3106; Section 3106, in turn, provides: that the trial court allowed the voir dire question, and that Appellant did not waive his challenge thereto.”
Com. v. Beatty, B., 2025 Pa. Super. 96 (Pa. Super. Ct. 2025).
· cites it 4× “____________________________________________ 5 18 Pa.C.S. § 3106 indicates that “[t]he credibility of a complainant of an offense under this chapter[, sexual offenses,] shall be determined by the same standard as is the credibility of a complainant of any other crime.”
Com. v. Perez, I. (Pa. Super. Ct. 2016).
· cites it 2× “” 18 Pa.C.S. § 3106. -7- J-S50008-16 Appellant’s argument that there was insufficient evidence because Victim did not communicate, either verbally or non-verbally, her lack of consent is without merit.”
Com. v. Hardy, Q. (Pa. Super. Ct. 2023).
· cites it 2× “See 18 Pa.C.S. § 3106 (“The testimony of a -6- J-S21038-23 complainant need not be corroborated in prosecutions under this [Sexual Offenses chapter of the Crimes Code]”).”
Com. v. Baker, P. (Pa. Super. Ct. 2023).
· cites it 2× “13B was derived from 18 Pa.C.S. § 3106, a statute pertaining to sexual assault cases, which provides: The credibility of a complainant of an offense under this chapter shall be determined by the same standard as is the credibility of a complainant of any other crime.”
Annotations are extracted automatically from the opinions in the
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treatment. Dots show Syfertize treatment of the citing case itself.