Muhammad v. State, 115 A.3d 742

Appellant Kamal Muhammad (a/k/a Melvin Caldwell) was convicted in Baltimore City of multiple offenses arising from a stabbing and sexual assault of L.M.
L.M. testified she was assaulted in a vacant row house; a DNA and SAFE examination corroborated injuries, while the state linked the knife and other items to the incident.
Detective Bell testified about L.M.’s post-incident interview at Shock Trauma, including a detailed narrative of the assault.
The trial court admitted Bell’s testimony as part of a prompt complaint of sexual assault exception to hearsay, and over defense objection.
Muhammad challenged the admission as beyond the scope of the prompt complaint exception; the court of appeals agreed to review this issue.
The court held admission of the detailed narrative was error and reversed, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bell’s testimony exceeded the prompt complaint scope	Muhammad argues it stayed within scope; the narrative was a proper prompt complaint.	Muhammad contends the details exceed the prompt complaint and bolster credibility.	Yes; admission exceeded scope and was reversible error.

Parker v. State, 67 Md. 329 (1887) (prompt complaint rationale and corroboration of victim's testimony)
Blake v. State, 157 Md. 75 (1929) (complaint testimony may include more than a yes/no question)
Green v. State, 161 Md. 75 (1931) (limits of complaint narrative and need for corroboration)
Cole v. State, 83 Md. App. 279 (1990) (narrative must not recount substance beyond basics of complaint)
Tyler v. State, 342 Md. 766 (1996) (limitations on admissible prior statements)
Mouzone v. State, 294 Md. 692 (1982) (prior statements exceeding scope)
Thomas v. State, 429 Md. 85 (2012) (prior consistent statements admissible under motive to fabricate rules)
Choate v. State, 214 Md. App. 118 (2013) (context of admissibility under prompt complaint exception)