People v. Brown

Opinion

GEORGE, J.

—Historically, under the common law fresh-complaint doctrine, evidence that the alleged victim of a sexual offense disclosed or reported the incident to another person shortly after its occurrence has been held admissible, as part of the prosecution’s case-in-chief, in a subsequent criminal prosecution for that offense. In California, the governing decisions have explained that the victim’s extrajudicial “complaint” is admissible for a limited, nonhearsay purpose—namely, simply to establish that such a complaint was made—in order to forestall the trier of fact from inferring…