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.