Commonwealth v. Stockhammer

Facts

Defendant and Complainant, at the time of the alleged rape, were both college freshmen, and friends. After spending a day with her boyfriend from out of town, Complainant and Defendant went to dinner together. Following dinner, Complainant and Defendant claim different events transpired. Complainant claimed that she and Defendant were alone in her room, and that she drank some alcohol; she asserted that Defendant did not drink any alcohol on the night in question. Complainant claimed that Defendant made sexual advances at her, but that she rejected the advances. Complainant then claims Defendant held her down and forced her to have sexual intercourse with her. According to Defendant, he and Complainant engaged in consensual fondling after dinner, and that he left thereafter to, “attend a previously scheduled engagement with some friends.” Defendant claimed that he returned later that night and had consensual sexual intercourse with Complainant. Nearly nine month later, Complainant, “ingested a large number of cold pills and was hospitalized.” Following her hospitalization, Complainant spent six days as an inpatient at a New York Medical Center, and also received outpatient counseling from a social worker. After the hospitalization, Complainant’s father received an anonymous call, telling him that Complainant, “was telling others that she had been sexually assaulted.” Complainant’s father confronted Complainant, and Complainant told him that she was in fact raped by Defendant. At trial, Defendant was allowed to view certain hospital records of Complainant’s, but was not allowed to view the social worker’s records, after the trial court held an in camera inspection and ruled them inadmissible. Defendant was unaware of and did not view the records from the New York Medical Center. Defendant was convicted of rape, and appealed that conviction here.