New York Court of Appeals
The People of the State of New York, Respondent v. Daniel A. Ludwig, Appellant
October 23, 201424 N.Y.3d 221
Summary
The Court affirmed the trial judge’s discretion to admit the victim’s prior consistent statements for the non‑hearsay purpose of explaining how the abuse was disclosed and the investigation began, and to exclude the defendant’s mother’s alleged prior inconsistent statement as inadmissible hearsay. The decision was contested by a dissent and a concurrence.