Nitz v. State
In Nitz v. State, 720 P.2d 55 (Alaska Ct. App. 1986), the defendant was convicted of a series of sexual assaults against his step-daughter. Id. at 58. The victim's first complaint was made to her mother. Id.
The victim subsequently made similar reports of defendant's conduct to a police officer, a social worker, and a physician. Id. at 58-59.
At trial, evidence regarding all of the victim's statements were admitted. Id. at 59.
The Court of Appeals of Alaska held that, under that State's first complaint doctrine, which allows for the admission of the initial complaint, only the victim's complaint to her mother was admissible at trial. Id. at 62-63.