People v. Rickman

Appeal by the defendant from a judgment of the Supreme Court, Kings County (Del Giudice, J.), rendered February 17, 2011, convicting him of robbery in the first degree, upon a jury verdict, and imposing sentence.

Ordered that the judgment is affirmed.

A witness’s trial testimony ordinarily may not be bolstered with pretrial statements (see People v McDaniel, 81 NY2d 10, 16 [1993]). However, evidence that a victim of sexual assault promptly complained about the incident is admissible to corroborate the allegation that an assault took place (see id. at 16). One limitation on the admissibility of…