People v. Sundling

Defendant was convicted, after bench trial, of aggravated criminal sexual abuse of two boys. No violation of confrontation clause, as victim testified at trial and defense could have cross-examined him, and court was able to examine extent of adult intervention. Mother's questions to victim, then age four, were not suggestive of anything untoward. Victim's statements, made after five-week delay, were not unreliable, given child's young age and his initial reluctance to discuss the abuse. Court within its discretion in finding victim's statements admissible under Section 115-10, as they were substantially consistent with another child's account, he did not recant, and statements were not induced by manipulation or leading questions. Memory-loss rule applies to victim as he could not recall some of details of encounter with Defendant. (JORGENSEN and BIRKETT, concurring.)