State v. Adam P.

Summary

The court overruled the prior modification of Connecticut’s constancy-of-accusation doctrine and restored the rule permitting jurors to consider a sexual-assault victim’s reporting delay when evaluating credibility, while limiting complaint evidence to corroborative purposes. It held that the challenged instruction was nonconstitutional and harmless because the charge as a whole preserved general credibility assessment, the defense did not principally rely on delayed reporting, and the state’s evidence was strong. The court also upheld admission of testimony that the defendant said he had played the same sexual “games” with his daughter, finding it relevant to grooming and adequately protected by limiting instructions.