Massachusetts Appeals Court hears challenge over police testimony, "first complaint" evidence in Juvenile case

Boston ' The Massachusetts Appeals Court on Tuesday, July 2, 2025, heard oral argument in Commonwealth v. (Juvenile), No. 24-P-89, on whether testimony by a school resource officer about a November 2019 conversation and subsequent investigative steps was admissible under the state's first-complaint doctrine and whether the defense's cross-examination was improperly restricted.

The issue matters because testimony that conveys the fact of a later complaint can be prejudicial: counsel for the juvenile argued the detective's testimony telegraphed that a complaint had been made and improperly corroborated the complainant's account, while the prosecutor said the testimony was limited background and tied to text-message evidence used by both sides.

Attorney Michelle Mankin, representing the juvenile, told the panel she would "like to address the testimony of detective Isabelle, both the first complaint doctrine issues and the restriction on the right of cross examination." Mankin argued the officer's testimony described subsequent investigative steps'contacting the student's parents, meeting with the student and parents, writing a report, referring the report to another agency and collecting Snapchat and text messages'and that…