Commonwealth v. Pineda-Mendoza

Following a jury-waived trial in the District Court, the defendant was convicted of indecent assault and battery on a person under the age of fourteen, G. L. c. 265, § 13B. On appeal, he claims that the judge erroneously allowed the victim's mother to testify as a first complaint witness and then restricted defense counsel's cross-examination of her, preventing the defendant from exposing the mother's bias and motive to lie. He further argues that the admission of multiple first complaint testimony requires reversal of his conviction. We affirm.

Background. The judge could have found the…