Brown v. Commonwealth

FITZPATRICK, Chief Judge.

Donald G. Brown (appellant) was convicted in a bench trial of taking indecent liberties with a child in violation of Code § 18.2-370. The sole issue on appeal is whether the trial court abused its discretion in allowing the testimony of the victim’s stepmother under the “recent complaint” exception to the hearsay rule. For the following reasons, we affirm appellant’s conviction.

I

Under familiar principles of appellate review, we examine the evidence in the light most favorable to the Common wealth, the prevailing party below, granting to it all reasonable inferences…