Lindsey v. Commonwealth
In Lindsey v. Commonwealth, 22 Va. App. 11, 467 S.E.2d 824 (1996), the Court affirmed the trial court's admission of a child's complaint made two years after the alleged incident.
The evidence established that "she had been too frightened to tell her mother about the incident." Id. at 14, 467 S.E.2d at 825.
The Court held that "while the lapse of time between the alleged event and the report is certainly an issue, it is a question of weight rather than of admissibility." Id. at 16, 467 S.E.2d at 827.