People v. Gonzalez, 80 N.Y.2d 853 (1992)
Under New York law, evidence of a prompt complaint of rape by the victim is admissible to show the reliability of that complaint, and the trial court has discretion to instruct the jury on the limited use of such evidence.
Summary
The New York Court of Appeals affirmed the Appellate Division’s order, holding that the trial court did not commit reversible error by instructing the jury on the use of prompt complaint evidence in a rape case. The defendant argued that the instruction unduly drew the jury’s attention to the evidence. However, the Court of Appeals reasoned that because the admissibility of prompt complaint evidence is established under New York law to show the reliability of the complaint, the trial court did not abuse its discretion by advising the jurors of the legal principles governing the use of that evidence. The defendant did not challenge the admissibility of the evidence itself, nor the substance of the instruction.
Facts
The defendant was convicted of rape. At trial, the prosecution presented evidence that the victim promptly complained of being raped. The defendant did not object to the admission of this evidence. The trial court instructed the jury that a prompt complaint lends some measure of reliability to the alleged victim’s story but is not proof of the facts and circumstances of the rape, for which other proof must be sought.
Procedural History
The defendant was convicted at trial. He appealed, arguing that the trial court erred by instructing the jury on the use of prompt complaint evidence. The Appellate Division affirmed the conviction. The defendant then appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court committed reversible error by instructing the jury on the use of prompt complaint evidence, over the defendant’s objection that the instruction would unduly draw the jury’s attention to the evidence, when the admissibility of such evidence was not challenged.
Holding
No, because proof that the victim promptly complained of being raped is admissible under existing law to show the reliability of that complaint, the trial court did not abuse its discretion by advising the jurors of the legal principles governing the use of that evidence in their deliberations.
Court’s Reasoning
The Court of Appeals focused on the fact that the defendant did not challenge the admissibility of the prompt complaint evidence itself, nor the substance of the trial court’s instruction. The court cited Boecio v. People and People v. Deitsch, affirming that prompt complaint evidence is admissible to show the reliability of the victim’s allegations. Because the evidence was properly admitted, the court reasoned, the trial judge was within their discretion to instruct the jury on how to consider the evidence, pursuant to CPL 300.10(2), which governs jury instructions. The court essentially held that a trial court has the authority to provide guidance to the jury on how to properly use admitted evidence. The court stated, “if, as defendant concedes, proof that the victim promptly complained of being raped is admissible, under existing law, to show the reliability of that complaint, it cannot be said that the trial court abused its discretion by advising the jurors of the legal principles which, defendant does not dispute, govern the use of that evidence in their deliberations.” There were no dissenting or concurring opinions noted.