Castelow v. Commonwealth
In Castelow v. Commonwealth, 29 Va. App. 305, 311, 512 S.E.2d 137, 139 (1999), the Court held that the trial court erred in allowing testimony of a child's stepmother that Castelow sexually molested the child.
The statement was made sixteen months after the alleged event and was inadmissible because "the evidence did not provide a proper foundation for the admission of the child's complaint to her stepmother." Id. at 310, 512 S.E.2d at 139.
The foundation was lacking because "no evidence in the record explains the delay of sixteen months." Id. at 312, 512 S.E.2d at 140.