Notwithstanding any other provision of law, in any prosecution for criminal sexual assault under Article 7 (§ 18.2-61 et seq.) of Chapter 4 of Title 18.2, a violation of §§ 18.2-361, 18.2-366, 18.2-370 or § 18.2-370.1, the fact that the person injured made complaint of the offense recently after commission of the offense is admissible, not as independent evidence of the offense, but for the purpose of corroborating the testimony of the complaining witness.
Va. Code Ann. § 19.2-268.2
Recent complaint hearsay exception (Subdivision (23) of Supreme Court Rule 2:803 derived from this section)
Applied in 3 court decisions — leading case 19 Va. App. 24 - Woodard v. Commonwealth (1994)
Most recently applied in Commonwealth v. Wills (February 1998)
1993, c. 592.
How often courts cite this section
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Official source: Virginia Law Portal (LIS). Reproduced from public-domain Virginia statutes; confirm against the official source for the current text. Not legal advice.