State v. Bethune

The opinion of the Court was delivered by

GARIBALDI, J.

In this appeal, as in State v. Hill, 121 N.J. 150, 578 A. 2d 370 (1990), also decided today, we consider the application of the fresh-complaint rule. This case involves the application of that rule to eases involving young children. Three issues are presented: (1) whether statements elicited from children who after being questioned complain of having been sexually abused retain the degree of self-motivation necessary to qualify under the fresh-complaint rule; (2) how much detail is permissible as part of a fresh complaint; and (3) what…