Bodine v. State

In Bodine v. State, 737 P.2d 1072 (Alaska App. 1987) the Court upheld admission of a child victim's inconsistent statements to social workers as substantive evidence under A.R.E. 801(d)(1)(A). In that case, the victim completely recanted her accusations of sexual abuse at trial. The court noted that "in determining the sufficiency of the foundation for admission of prior inconsistent statements, the trial court is allowed considerable latitude, particularly where the witness is a young child." The court further found that "although the prosecutor could certainly have been more specific in disclosing to the victim the date of her prior statements, the persons to whom they were made, and their precise contents, the questions actually asked were, in context, adequate to alert the victim to her prior interviews with a social worker and a police officer and to the general subject matter related therein."