State v. WB, 17 A.3d 187

Defendant was convicted of first-degree aggravated sexual assault, second-degree sexual assault, second-degree endangering the welfare of a child, and fourth-degree aggravated criminal sexual contact for abusing his fourteen-year-old stepdaughter, D.L., with a videotaped confession central to proof.
The State introduced D.L.'s prior inconsistent statement, CSAAS testimony by Dr. Coco, fresh-complaint testimony from D.L.'s boyfriend J.C., and the videotaped confession.
The trial court admitted D.L.'s statements, the CSAAS testimony, and J.C.'s testimony; the defense highlighted Miranda/voluntariness and discovery issues.
D.L. recanted at trial; D.L. testified the investigators’ statement was false; defendant offered his own account of events.
Appellate Division affirmed the convictions. The Supreme Court affirmed, with rulings on admissibility of CSAAS, discovery notes, fresh-complaint evidence, and playback of the videotape.
Dissent criticized the majority for allowing improper credibility-inference and other procedural missteps to sustain the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of the defendant's statement	State argued voluntary and properly Miranda-warned	Defense argued involuntary due to custodial coercion and irregularities	Statement admissible; voluntary waiver found
CSAAS testimony and its credibility impact	CSAAS admissible to explain victim behaviors	CSAAS statistics and credibility use improper	CSAAS testimony limited; no use to prove abuse; statistics inadmissible; overall not reversible error
Destruction of contemporaneous notes and discovery sanction	Notes not required to be preserved after report	Notes should be preserved; potential adverse inference	Adverse inference charge postponed; preservation rule clarified for future cases
Fresh-complaint admissibility timing	Fresh complaint admissible to rebut silence inference	Fifteen-month delay beyond reasonable time	Fresh complaint admissible under flexible standard for child victims; timing deemed reasonable in context
Playback of videotaped confession before jury not in evidence	Playback allowed as part of trial record	Tape not admitted; improper playback during deliberations	Playback not reversible error; no abuse given context and prior in-court playbacks

State v. Nyhammer, 197 N.J. 383 (N.J. 2009) (voluntariness analysis in custodial interrogation)
State v. J.Q., 130 N.J. 554 (N.J. 1993) (CSAAS admissible for limited psychological explanation; not for proving abuse)
State v. P.H., 178 N.J. 378 (N.J. 2004) (fresh-complaint and CSAAS framework; jury instructions guidance)
State v. Bethune, 121 N.J. 137 (N.J. 1990) (reasonable time for fresh complaint; flexibility for children)
State v. Hill, 121 N.J. 150 (N.J. 1990) (fresh-complaint admissibility criteria; spontaneity requirement)