In Re LC, 41 A.3d 1261

A.M., a ten-year-old, testified that L.C., a fourteen-year-old, sexually assaulted her at a pool during a summer camp activity.
L.C. was convicted of first-degree sexual abuse and first-degree child sexual abuse based on A.M.'s testimony.
Before trial, L.C. moved to exclude A.M.'s out-of-court statements under the report-of-rape exception, arguing it does not apply in bench trials.
The trial court admitted the statements, finding A.M. credible and corroborated by multiple witnesses (nurse, male counselor, camp director).
On appeal, L.C. argues the report-of-rape exception does not apply in bench trials; the DC Court of Appeals must decide its applicability in bench trials.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the report-of-rape exception applies in bench trials	L.C. argues no, based on Battle's focus on jurors','prejudices	State argues rule applies to bench trials as society's prejudices; judges are subject to same social assumptions	Yes; rule applies in bench trials to the same extent as jury trials

Battle v. United States, 630 A.2d 211 (D.C.1993) (report-of-rape rule survives corroboration abolition; admissibility for purpose of showing a report was made)
Cullen v. United States, 886 A.2d 870 (D.C.2005) (acknowledges report-of-rape rule in bench trials)
Mattete v. United States, 902 A.2d 113 (D.C.2006) (implicitly endorsed bench-trial admission under Battle)
Dyson v. United States, 848 A.2d 603 (D.C.2004) (de novo review of hearsay exceptions; abuse of discretion standard for admissibility)
Daye v. United States, 733 A.2d 321 (D.C.1999) (prior consistent statements to bolster credibility; exceptions in sex-offense context)
Duncan v. Louisiana, 313 U.S. 145 (U.S. 1968) (historical jury valued in safeguarding against bias; societal assumptions affect fact-finding)
Battle v. United States, 630 A.2d 211 (D.C.1993) (reiterates rationale for report-of-rape rule in context of jurors' prejudices)