New York Court of Appeals
The People of the State of New York v. Angel Rosario, Respondent the People of the State of New York v. Luis Parada
October 18, 201117 N.Y.3d 501
Summary
The Court of Appeals affirmed the Appellate Division’s rulings that the victim’s prior consistent statement was inadmissible as a prompt outcry and not admissible to rebut a recent fabrication claim in People v. Rosario, and that the victim’s prior consistent statement to a cousin was admissible as a prompt outcry and the admission of a statement to an aunt was harmless error in People v. Parada.