State of Connecticut v. Daniel W. E.

Summary

The court affirmed the defendant's convictions, holding that the jury instruction properly limited constancy of accusation evidence to evaluating the fact and timing of the victim's complaints and related identifying details, rather than the truth of those complaints. The court nevertheless prospectively modified the constancy doctrine so that constancy witnesses may testify only when the defendant challenges the victim's credibility concerning delayed reporting or prior complaints; otherwise, the jury must be instructed not to use the delay against the victim. Justice Espinosa, concurring, agreed with the affirmance and the instructional ruling but would have left the existing doctrine unchanged.