In Test of First Complaint Doctrine, Appeals Court Affirms Multiple Rape Convictions

SUMMARY: The Massachusetts Appeals Court affirmed a defendant’s convictions on four counts of rape, despite the fact that the events at trial violated a strict interpretation of the First Complaint doctrine, and, additionally, separate First Complaint witnesses/evidence were proffered for the separate rapes. CASE NAME: Commonwealth v. Lewis,_____ Mass. App. Ct. ____ (2017), No. 16-P-257, decided June 7, 2017. DECISION: Unanimous affirmation, 3-0, opinion by Justice Hanlon. JUSTICES: Justice Sydney