State v. Livingston

OPINION

CHARLES H. O’BRIEN, Special Justice and BIRCH, Justice.

We accepted the application for review filed pursuant to Rule 11, Tenn.RA.pp. P., in these four cases in order to determine whether the fresh-complaint doctrine recently modified in State v. Kendricks 1 applies in cases wherein a child is the victim of abuse. For the reasons below appearing, we hold that the fresh-complaint doctrine does not apply in such cases.

As a related issue, one of the cases under submission (Livingston) presents an opportunity for us to clarify' the circumstances under which statements made by a child victim…