State of Tennessee v. Jerrell C. Livingston, State of Tennessee v. Steve Bundy, State of Tennessee v. John R. Tilley, & State of Tennessee v. David Johnson

We accepted the application for review filed pursuant to Rule 11, Tenn. R. App.P. In these four cases in order to determine whether the fresh-complaint doctrine recently modified in State v. Kendricks 1 applies in cases wherein a child is the victim of abuse. For the reasons below appearing, we hold that the fresh-complaint doctrine does not apply in such cases.