Commonwealth v. Edwards

1. As we read the record, the judge was never asked to rule on the question whether the victim’s first complaint to her mother was too remote in time (approximately a day and a half following the rape) to qualify for admission in evidence as a fresh complaint. See Commonwealth v. Bailey, 370 Mass. 388, 391-397 (1976). The only objection ever articulated to either the fact or the content of that complaint was "hearsay”; there was no request for a limiting instruction as to the purpose for which the jury might properly consider a fresh complaint, either when the questions were asked of the…