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THE DISCLOSURE PROCESS AMONG VICTIMS OF CHILD SEXUAL ABUSE and IMPLICATIONS FOR FORENSIC INTERVIEWERS, INVESTIGATORS, AND THERAPISTS. . L. Dennison Reed, Psy.D NSU CPS. Questions to be addressed in this presentation:. Why are some CSA victims reluctant or unwilling to disclose their abuse?

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L. Dennison Reed, Psy.D


questions to be addressed in this presentation
Questions to be addressedin this presentation:
  • Why are some CSA victims reluctant or unwilling to disclose their abuse?
  • Which CSA victims are least likely to disclose their abuse during a forensic interview?
  • Which CSA victims are most likely to disclose their abuse during a forensic interview?
  • What can forensic interviewers and therapists do to encourage reluctant children who have been abused to disclose their abuse?
  • What can forensic interviewers and therapists do to help protect abused children that deny their abuse, delay reporting, or recant their allegations?
Due to limitations in our knowledge about the disclosure of CSA, it is impossible to know what proportion of victims disclose
  • Our information about the disclosure process is limited to samples of identified victims
  • Unidentified victims are excluded:
    • Children who never disclosed their abuse to anyone
    • Children who disclosed to ‘someone’ but whose abuse was never reported to the authorities
    • Children whose abuse was reported, but was erroneously classified as “unsubstantiated”
    • Adults who were sexually abused as children but who deny their abuse during retrospective surveys

Although the exact rates of non-disclosure of CSA cannot be determined, data from known and likely victims suggest that non-disclosure rates are quite substantial

information about the disclosure process is drawn from two sources
Information about the Disclosure Process Is Drawn From Two Sources
  • Adults who reported (to researchers) that they were sexually abused as children
  • Children who are “confirmed victims” of CSA
retrospective studies of adults have found that non disclosure during childhood is very common
Retrospective studies of Adults have found that NON-DISCLOSURE during childhood is very common
  • Approximately TWO-THIRDS [60-70%] of adults who reported (during retrospective studies) that they were molested as children say they did not disclose their abuse to anyone during childhood (not even to a friend or a parent)

London, et al (2007)

even severe child sexual abuse is rarely reported to the authorities
Even ‘severe’ child sexual abuse is rarely reported to the authorities
  • A nationally representative retrospective survey of over 4000 American women, found that only 12%of childhood “rapes” were reported to the authorities
  • “Rapes” were defined as nonconsensual sexual penetration of the victim’s vagina, anus or mouth by the perpetrator’s penis, finger, tongue or an object that involved the use of force or the threat of force or coercion.

Rochelle F. Hanson et al (1999). Factors Related to the Reporting of Childhood Rape, Child Abuse & Neglect, 23, 559- 569

which children were most likely to disclose their abuse to someone during childhood
Which children were most likely to disclose their abuse to “someone” during childhood?
  • Retrospective studies have found that adults who experienced CSA during adolescence were more likely to have disclosed their abuse to someone than those who were abused at a younger age.
  • They most commonly disclosed to a peer.

(Bruck, et al, 2007)

disclosure data from child samples in high certainty cases
  • Diagnostic medical evidence of CSA (e.g., STDs)
  • Audiovisual evidence (e.g., videotapes of the abuse)
Even When There Is Diagnostic Medical Evidence of Sexual Abuse, Many Children Still Fail To Disclose Their Abuse
  • Across 21 studies examining gonorrhea in children, the average disclosure rate was only 43%
  • Having an unsupportive parent was a strong predictor of non-disclosure
  • Thus, when screened for sexual abuse, MOST children with gonorrhea denied they were abused

Lyon (2007)

A substantial proportion of sexually abused children failed to disclose their abuse even though there were VIDEOTAPES of the abuse
  • Videotapes were discovered depicting a man sexually abusing 10 different children (9 boys, 1 girl)
  • None of the children disclosed their sexual abuse to anyone prior to being interviewed by the police
  • Half denied the abuse when interviewed by the police. Those who did disclose minimized the extent of the abuse
what do children s denials of abuse mean about the likelihood of abuse
What do children’s denials of abuse mean about the likelihood of abuse?
  • “. . . to the extent that denial rates are surprisingly high, an expert can justifiably testify that that denials are surprisingly weak evidence that abuse did not occur

Lyon, T. (2007). False denials: Overcoming methodological biases in abuse disclosure research. In Child Sexual Abuse: Disclosure, Delay and Denial. Pipe, et al. Ed.

delayed disclosure is common both in retrospective studies of adults and in child samples
Delayed disclosure is common bothin retrospective studies of adults and in child samples
  • Disclosure is often a ‘process’ that occurs over time rather than being a single ‘event’
  • Multiple interviews may be necessary with some children; however, this also increases the risk of leading some non-abused children to make false allegations IF the interviews are suggestive
sexual naivet


-Youngand sexually naïve children may not even realize that they have been abused.

Molesters who target younger children often misrepresent the abuse as something innocent:

Game or playful activity, i.e., tickling, wrestling

display of affection

hygiene practice


Drum lessons

sexual modesty


Children receive “modesty training” about sexual topics early on.

“Private” Parts


NON-ABUSED CHILDREN’S REPORTS OF VAGINAL AND ANAL TOUCHING DURING A MEDICAL EXAM5 and 7 year old girls(Saywitz, Goodman, Nicholas & Moan, 1991)

sample n 72 females 5 7 year olds
SampleN = 72 females5 & 7 year-olds

Half (36) of the children received a routine medical exam, including a vaginal and anal exam. The other half received a routine medical exam, but with a scoliosis (spinal) exam instead of a vaginal and anal exam.

STAGE 1OPEN-ENDED QUESTIONINGNO ANATOMICAL DOLLS“Tell me everything you remember about your visit to the doctor.”
  • 22% Disclosed Vaginal touching
  • 11% Disclosed Anal touching

STAGE 2OPEN-ENDED QUESTIONING WITH ANATOMICAL DOLLS“Show and tell me what happened when you went to the doctor’s” (using anatomical dolls and medical props)

  • 17% Disclosed Vaginal touching
  • 11% Disclosed Anal touching
  • Note: Lower rate of disclosure of vaginal touching when anatomical dolls were used (22% vs. 17%)

STAGE 3‘YES/NO’ (Option-posing) QUESTIONSWITH ANATOMICAL DOLLS“Did the doctor touch you there?” (pointing to various body parts on anatomical dolls)

  • 86% Disclosed Vaginal touching
  • 69% Disclosed Anal touching
False Reports of Genital and Anal Touching by 5 & 7 year olds(Scoliosis Condition) Anatomical dolls + option-posing questions
  • One of the 36 children (< 3%) erroneously answered “yes” when asked if doctor touched the vaginal area.
  • Two (< 6%) erroneously answered “yes” when asked if doctor touched the anal area.
  • Only one of these three children were able to provide any detail about the alleged touching.
misplaced guilt
  • Many sexually abused children feel at least partially responsible for their own abuse
    • “It was my fault” (e.g., It was because I dressed that way; It was because I didn’t lock my door; It was because I was too pretty)
    • “I should have stopped him/her”
    • “I should have told the very first time”
  • Many sexually abused children feel guilty for having become sexually aroused during their abuse

For many sexually abused children, disclosing their abuse feels more like confessing a sin, than reporting a crime

Their misplaced sense of guilt is a powerful motivator for keeping their abuse a secret

STIGMA and SHAMEPre-teen and teenaged BOYS are often extremely reluctant to disclose abuse by a MALE
  • “Homophobia” is rampant among boys this age
  • This sense of shame can be reinforced by the victim experiencing an erection during the abuse
secrecy pacts
Secrecy Pacts
  • Child molesters sometimes directly ask or entice the child to keep the abuse a secret
    • This is our little secret so don’t tell anyone else, ok?
    • Here’s a new video game because you’ve been doing really good at keeping our secret
fears of separation rejection
  • Victims may fear that if they tell they will be separated from loved ones--including the perpetrator who is oftentimes a beloved relative or friend. The child may be confused or repulsed by the abuse, but still love or care for the abuser
  • The victim may fear that if she discloses the abuse, loved ones will be angry with her and will blame her for :
    • Lying/making false allegations
    • Not telling earlier; “seducing” the perpetrator
    • Causing family hardships by disclosing the abuse
not wanting to get the offender in trouble
  • The child may be confused or even repulsed by the abuse but still have loving feelings for the abuser
    • “I hate what he did to me, but he’s still my father”
  • Male molesters who target boys are especially masterful at befriending their victims and ensuring that they remain ‘loyal’
threats of physical harm
  • To the victim
  • To the victim’s loved ones, i.e., parents, siblings, pets
  • BUT, threats of physical harm are rarely needed to maintain secrecy
dissociation and ptsd related amnesia
Dissociation and PTSD-related Amnesia

This is far more likely when the abuse is terrifying, painful, repetitive and emotionally or physically intolerable for the child.

“Whenever he did that, I went to the pink forest.”

“I left my body and hid in a crack in the wall.”

“I watched Mickey Mouse cartoons in my head when it started to hurt real bad.”

“I think I was sleeping.”

PTSD and Dissociative amnesia can give rise to delayed memories and flashbacks

factors that inhibit disclosure
Factors that Inhibit Disclosure
  • Sexual Naiveté
  • Sexual Modesty
  • Misplaced Guilt
  • Stigma and Shame
  • Fears of Separation and Rejection
  • Secrecy Pacts
  • Affectionate feelings for the offender
  • Threats of Physical Harm
  • Dissociation and PTSD-related amnesia
which kids are most likely to disclose during a forensic interview
Which kids are most likely to disclose during a forensic interview?
  • Kids who made a prior disclosure to someone, e.g., parent, teacher, therapist
  • Older children
  • Kids who are not related to the perpetrator
  • Kids whose parents are supportive of them and are willing to consider the possibility that their child was sexually abused
The best predictor of disclosure during a forensic interview is the child having made a prior disclosure to someone
which kids are least likely to disclose during a forensic interview
Which kids are least likely to disclose during a forensic interview?
  • Kids who have not made a prior disclosure (e.g., to a parent)
  • Kids ages 3-6
  • Kids abused by a relative
  • Kids whose parents are not supportive
    • Children’s reluctance and guardedness is typically obvious very early in the forensic interview—even before abuse-related (substantive) questioning begins
the power of parental support
The Power of Parental Support
  • Children with STDs (e.g., gonorrhea) were questioned about possible abuse during a forensic interview
  • When their parents rejected the possibility that they were sexually abused, only 17% disclosed
  • 67% of children whose parents were open to the possibility that their child had been sexually abused disclosed their sexual abuse

Lawson, L. & Chaffin, M. (1992).

develop rapport with the child

Sexually abused children’s embarrassment and shame, misplaced guilt, fears about disclosing to an unfamiliar adult, and lack of trust in the interviewer are barriers to disclosure.

Developing rapport with children enhances their sense safety and their belief that the interviewer genuinely cares about them, is interested in them, and is a safe person to talk about distressing topics like sexual abuse.

rapport building is not a stage in the forensic interview process
Rapport building is not a ‘stage’ in the forensic interview process
  • Rapport building should begin when you first introduce yourself to the child and should continue throughout the entire interview.
rapport building techniques non verbal communication
Rapport Building TechniquesNon-verbal Communication


Victor Borges, a Danish comedian, said, “A smile is the shortest distance between two people.”

Use a warm and friendly tone of voice

Speak s-l-o-w-l-y, and maintain a calm appearance

Maintain appropriate eye contact

Use gestures that convey interest, patience and caring

rapport building techniques introductory phase and beyond
Rapport Building TechniquesIntroductory Phase and beyond

Address the child by name:

“Hello Cindy. My name is _____. I’m so glad to meet you!”

Provide appropriate compliments:

“Those sure are cool shoes you have on today.”

rapport building techniques discuss something fun at the outset
Rapport Building TechniquesDiscuss something ‘fun’ at the outset

At the outset (before ‘ground rules,’ abuse Qs), ask in a friendly and interested manner about something the child likes to do for fun, or a recent event that the child enjoyed:

“What do you like to do for fun?” “Tell me all about that.”

“You said you had lots of fun at your birthday party. Tell me all about your birthday party.”

Follow-up with non-leading, open-ended questions; and thank the child for ‘telling you all about it.’ This ‘practice narrative’ also prepares the child to provide detailed responses when you inquire about abuse later on. (‘Revised’ NICHD Protocol)


rapport building techniques convey concern about the child s comfort
Rapport Building TechniquesConvey concern about the child’s comfort

Show concern about the child’s comfort at the outset (and throughout the interview)

“How are you doing today?”

“It’s real important to me that you are as comfortable as you can be while we are together today. So be sure to let me know if you need to go to the bathroom or to get a drink, or if I can do anything to make you more comfortable, okay?”

rapport building techniques convey interest throughout
Rapport Building TechniquesConvey ‘interest’ throughout
  • Show an interest in things the child is interested in, even if it is not “forensically relevant.”
rapport building techniques reassure the child that you are comfortable with the interview process
Rapport Building TechniquesReassure the child that YOU are comfortable with the interview process
  • Convey your experience with kids:
    • “I talk to lot’s of kids about things that have happened to them. And they tell me about all kinds of things.”
  • ‘Normalize’ the process; avoid showing signs of shock, distress, or disapproval:
    • “It’s okay to talk about ‘anything’ with me.”
    • “It’s okay to say those (bad) words here.”
    • “I can’t believe he did that. How disgusting!”
rapport building techniques minimize the child s guilt embarrassment
Rapport Building TechniquesMinimize the child’s guilt & embarrassment
  • When the child reports abuse but seems to feel guilty or embarrassed about it, provide encouragement and reassurance:
    • “I’ve talked to lots of kids who have had things like this happen to them. You can trust me and tell me about the things that have happened to you.”
    • “When grown-ups do things like this to a child, it’s not the child’s fault.”
rapport building techniques give permission to disclose secrets
Rapport Building TechniquesGive permission to disclose secrets
  • To address secrecy:
    • “Many kids have secrets that they do not talk about. If you have a secret, I am someone you can trust to tell secrets to.”
rapport building techniques provide positive reinforcement for effort
Rapport Building TechniquesProvide positive reinforcement for ‘effort’

Provide thanks, appreciation, and positive reinforcement for the child’s efforts (not for specific content, e.g., abuse allegations)

“Thank you for telling me all about that.”

“You’re really helping me understand.”

“You’re paying such good attention to my questions.”

rapport building techniques convey empathy for the child s distress
Rapport Building TechniquesConvey empathy for the child’s distress
  • Show empathy for the child’s feelings and difficulties regarding the interview process and provide encouragement and offer help when appropriate (but be cautious about focusing on the abuse experience):
    • “I know it’s hard answering so many questions. And you’ve been doing a really good job.”
    • “If its hard for you to talk about, is there something I can do to make it easier?”
rapport building techniques offer alternative means of communication
Rapport Building TechniquesOffer alternative means of communication
  • If the child simply won’t or can’t talk about it despite your best efforts, offer an alternative:
    • “Would it be easier for you to write it down?
    • “Would it be easier for you to draw a picture of what happened?”
    • “Would it be easier for you to say what happened if I leave the room?”
other strategies for overcoming reluctance consider changing interviewers
Other Strategies for Overcoming ReluctanceConsider changing interviewers
  • Gendercan be a factor, i.e., child might be more comfortable speaking to a female than to a male. In this case, it might also be helpful have any male investigators to leave the room
  • Race or ethnicity can be a factor. Children sometimes are more willing to disclose to those of the same race/ethnicity.
other strategies for overcoming reluctance what if i talked to
Other Strategies for Overcoming Reluctance “What if I talked to ( )?”
  • “What if I talked to (another potential victim or witness; child’s sibling, etc.), what would she/he tell me?”
  • “What if I talked to (non-offending parent; reporter), what would she/he tell me?”
  • “What if I talked to (suspected perpetrator) what would he say?”
When all other interview approaches fail, consider including the person the child disclosed to previously
  • This is a risky option, but it may be justified—especially when there is other strong evidence of abuse.
  • Children are sometimes more willing to repeat their allegations in the presence of or to the person they have already disclosed to.
  • The interviewer must ‘control’ the interview to avoid potential influencing/leading by the other person, e.g., explicit instructions re. seating arrangements, comments/questions/reactions. Asking a parent not to ‘lead’ the child is insufficient! Providing written questions and ongoing guidance (via ‘bug in the ear’) can reduce the risk of improper questioning
pressure coercion don t work don t swim against the current
PRESSURE & COERCION DON’T WORKDon’t swim against the current!
  • Pressuring reluctant children to discuss abuse before the are ready usually makes them all the more reluctant to disclose. Patience is critical!
  • Some children require more time and more rapport building before they will open up; and some will need to be interviewed more than once. But the interviewer needs to be especially careful to avoid asking leading questions.
  • Research has shown that many children who are interviewed on multiple occasions using open-ended questions provide very reliable and detailed allegations.
some kids will not disclose their abuse to even the most skilled interviewer
Some kids will not disclose their abuse to even the most skilled interviewer
  • But the forensic interview is not the only potential source of evidence:
    • Suspect interview (confession)
    • Crime scene
    • Witnesses
    • Medical evidence
recantation can occur at any time after the initial disclosure
Recantation Can Occur At Any TimeAfter the Initial Disclosure
  • When pressured by the perpetrator, family members, etc.
  • When interviewed by investigators
  • While in therapy
  • In anticipation of testifying
  • While testifying during a deposition
  • While testifying at trial
  • After the trial
why do sexually abused children sometimes recant their valid allegations of abuse
Why Do Sexually Abused Children Sometimes Recant Their Valid Allegations of Abuse?
  • For the same reasons that children fail to reveal their sexual abuse in the first place
  • Also, negative reactions to the disclosure can be a very potent cause of recantation:
    • Parent appears overwhelmed, hysterical, angry and “out of control” -- this is especially upsetting for younger children
    • Parent blames victim for not resisting the abuse; for ‘seducing’ the abuser; or for not disclosing earlier
    • Family members are angry at victim for creating hardships for the family
other reasons sexually abused children sometimes recant their valid allegations of abuse
Other Reasons Sexually Abused Children Sometimes Recant Their Valid Allegations of Abuse
  • The child is separated from the family, e.g., placed in foster care
  • Threats/enticements by perpetrator or others to recant
  • To ‘rescue’ the perpetrator
  • Stress associated with involvement in the legal system, e.g., having to testify
a case of recantation occurring during a deposition
A Case of Recantation Occurring During a Deposition

St. of Florida vs. James “Jimmy” Heuss

james jimmy heuss background information
James “Jimmy” HeussBackground Information

Heuss molested several young girls while he was in the Navy -- General Discharge

Moved to Texas. Convicted of molesting several young girls -- Outpatient sex offender treatment--“model patient”

Moved to southern Florida. Sexually assaulted a3-year-old girl. There was medical evidence of penetration -- Case dropped when the victim’s parents refused to subject child to the legal process

While living in Ft. Lauderdale, Heuss molested three female cousins ages 4 & 5 whom he was babysitting. The abuse involved fondling and oral sex and, for one of the girls, digitally penetration. There was medical evidence of penetration.

all three girls disclosed the abuse
All three girls Disclosed the Abuse

The parents of the children first learned of the abuse after the fiancé of the mother of 5-year-old Child A informed her that he observed Child A performing oral sex on her 3-year-old brother. When the mother confronted her daughter, she explained that she had learned it from Heuss when he did the same thing to her.

This led to acknowledgment by the other two girls that ‘Jimmy’ had sexually abused them, too.

Despite being very young, all three girls gave very credible statements to the police

statement of 5 year old child a to a police officer
Statement of 5-year-old Child A to a Police Officer

After her initial disclosure to her mother (after being caught performing oral sex on her 3-year-old brother), Child A provided a spontaneous and detailed description of the abuse to a police officer:

Jimmy took her into his bathroom, locked the door, pulled her panties down, put her on the rug on the bathroom floor and licked her privates (identified as vaginal area). She could feel his tongue on her privates. Afterwards, he told her not to tell anyone about what had happened

statement of 5 year old child a to the prosecutor
Statement of 5-year-old Child A to the Prosecutor

Child A repeated the allegations she had made to the police officer, and provided additional details, e.g., description of “Jimmy’s” residence, the clothes she was wearing, the rug he placed her on before performing oral sex on her, etc.

during their deposition two of the three girls recanted their sexual abuse allegations
During their Deposition, two of the three girls RECANTED their sexual abuse allegations

Excerpt from deposition of Child A

deposition of 5 year old child a
Deposition of 5-year-old Child A

Denied ever being in Jimmy’s bathroom

Denied ever telling mom or anyone else that Jimmy did something bad

Denied anybody tried to take her pants off

Denied anyone touched her private

Denied telling the police officer that Jimmy put her on the rug and licked her private:

“He never did that”


In Most Jurisdictions (including Florida), Courts Allow ‘Rehabilitative Testimony’ to Inform Jurors that Recantation is Not Uncommon Among Sexually Abused Children


Caveats on Rehabilitative (Rebuttal) Testimony From “Expert Testimony Offered to Rehabilitate A Child’s Credibility” in Myers on Evidence in Child, Domestic and Elder Abuse Cases (2005)

Should only be introduced AFTER the defense suggests that the child’s abuse allegations are not credible because the child denied or recanted at some point

The Expert Witness can explain that recantation is not uncommon among sexually abused children and can explain why some sexually abused children recant their valid allegations--but should avoid referring directly to the alleged victim(s) in the case at hand

But, the Expert Witness cannot comment on the credibility or truthfulness of the alleged victim

st vs james heuss the trial
St. vs. James HeussThe Trial

All three girls testified that Jimmy had sexually abused them

The Defense argued that the girls’ abuse allegations were not credible because they had recanted during their deposition

Dr. Reed provided ‘Rehabilitative Testimony’ explaining that recantation is not uncommon among sexually abused children in general, and explained why some victims recant

st vs james heuss the trial verdict
St. vs. James HeussThe Trial Verdict

Guilty on all charges: two counts of sexual battery and one count of lewd assault

Defense appealed the guilty verdicts arguing, in part, that the Expert Witness improperly ‘vouched’ for the children’s credibility

st vs james heuss the appellate court ruling
St. vs. James Heuss The Appellate Court Ruling

The 4th DCA (FL) found that the Expert Witness had not commented on the victims’ credibility and had discussed the recantation phenomenon in general terms without referring specifically to the alleged victims in this case, which is permissible

Heuss’ conviction was UPHELD by the 4th DCA

jimmy heuss where is he today
Jimmy HeussWhere is he today?

Heuss is serving two consecutive life sentences without parole

many sexually abused children provide inconsistent contradictory statements about their abuse
Many sexually abused children provide inconsistent & contradictory statements about their abuse

Since a substantial portion of sexually abused children go through various stages of disclosure (e.g., denial, minimization, progressively disclosing more abuse, recanting their abuse allegation) inconsistencies and contradictions in their accounts are not uncommon and do not “prove” that sexual abuse did not occur


Under certain conditions, Florida Courts accept ‘rehabilitative testimony’ by experts to explain why child sexual abuse victims sometimes:delay in reporting the abuserecant their earlier abuse allegationsprovide inconsistent statements

  • Do rely solely on the expert’s professional training and experience (i.e., “pure opinion”)
  • Do refer only to sexually abused children in general (and not to the alleged victim)

Recent Florida Case Law Supporting the Use of Expert Rehabilitative Testimony Regarding Common Behaviors Seen Among Sexually Abused Children (e.g., delayed disclosure, initial denial, peace meal disclosure

oliver v state 977 so 2d 673 677 5th dca 2008
Oliver v. State, 977 So.2d 673, 677 (5th DCA 2008)

“[The psychologist] testified that although there was “no single post sexual abuse syndrome” and “no way to look at a child and say this child's been sexually abused,” there were some typical behaviors. These included (1) the victim's desire to act “hyper-normal” after being sexually abused; (2) denying sexual abuse at first; (3) delaying disclosure; (4) disclosing the facts in piecemeal fashion; and (5) the victim's attempts to control their emotions . . . In this case, Dr. Dikel carefully couched his testimony solely in relation to his professional experience. Thus, it was pure opinion testimony not subject to Frye.”

baugh v state 28 fla l weekly d 2511 2 nd dca fla 2003 victim recants at trial
Baugh v. State 28 Fla. L. Weekly D 2511 (2nd DCA Fla. 2003) Victim Recants at Trial

Defendant was accused of making his girlfriend's daughter perform oral sex on him. At trial, the evidence was almost exclusively pretrial unsworn hearsay statements by the child victim, which were admitted under Fla. Stat. ch. 90.803(23) (2000). Defendant admitted to having wanted the victim to perform oral sex, but he contended this was said in the heat of an argument to incite the mother. The victim's in-court testimony directly contradicted the earlier statements [victim RECANTED]. However, the State presented evidence to corroborate the victim's initial statements, such as defendant's immediate suicide attempt and statements by him that he had engaged in witness tampering. Defendant was convicted and he appealed. The court held that the prior statements, on their own, were insufficient to sustain the conviction. However, the other evidenceallowed the inference of defendant having committed the crime.The conviction was upheld!