People v. Rosario

*601The trial court improperly admitted into evidence a prior consistent statement by the complainant, thereby allowing the impermissible bolstering of the complainant’s testimony (see People v McDaniel, 81 NY2d 10, 16 [1993]; People v McClean, 69 NY2d 426, 428 [1987]; People v Van Ness, 43 AD3d 553, 554-555 [2007], lv denied 9 NY3d 965 [2007]), an error that is especially prejudicial when the complainant’s credibility is the linchpin of a conviction. The note that the complainant wrote approximately one year before she made the accusation to the police cannot satisfy the “prompt outcry”…