State of New Jersey, Plaintiff-Respondent v. Joseph Bethune, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the conviction, holding that a child’s statement elicited by non‑coercive questioning can satisfy the fresh‑complaint rule, that only the fact of the complaint—not detailed narration—is admissible, that jury instructions must limit fresh‑complaint evidence to negating an inference of silence, and that any error in admitting such testimony was harmless given other corroborating evidence and the tender‑years exception.