concurring.
I write separately to explain my views on the hearsay issues in this case.
C.B.'s report of sexual abuse to her school friend, C.K., was properly admitted under the "first complaint" exception to the hearsay rule. When C.B. confided in C.K., this was C.B.'s first report of the sexual abuse; moreover, C.K.'s description of the report was fairly short and did not include many details.
With regard to C.B.'s later reports to her teacher and to the school nurse, the trial judge ruled that C.B.'s statements to these two adults were admissible to establish the course of the investigation. This was a permissible basis for the testimony; but if this was the sole ground for allowing the teacher and the school nurse to testify, they should not have been allowed to give the details of C.B.'s report-only that C.B. claimed to have been sexually abused, and that they alerted the authorities.
If I were writing on a clean slate, I would be inclined to expand the "first complaint" exception to the cireumstances of this case: cireumstances where a child victim first confides the sexual abuse to a peer, and then later confides in an adult who is in a position to help. (In the present case, C.B.'s reports to her teacher and the school nurse took place within a span of minutes; they were essentially a single continuing report.) But even under a strict construction of the "first complaint" rule, I conclude that any error in allowing the teacher and the school nurse to recite the details of C.B.'s report does not require reversal of Strumsky's conviction.
*506The testimony of both the teacher and the school nurse was fairly short, and neither of them offered many details of the offense. The small detail that these two witnesses offered was nothing compared to the amount of detail contained in C.B.'s own testimony, which went on for hours and which preceded the testimony of these other witnesses.1 Further, it is clear from the record that C.B. was a competent witness whose credibility could be judged in the same manner as typical witnesses. C.B. was not an inarticulate youngster whose account of the abuse was presented primarily through the testimony of adults.2 Thus, any arguable error in allowing C.B.'s teacher and her school nurse to cursorily repeat C.B.'s report of sexual abuse was harmless.
This leaves the question of whether the trial judge should have admitted the testimony of Detective Bales. Strumsky's attorney objected on hearsay grounds when Bales was asked to describe C.B.'s report of sexual abuse. Because the prosecutor responded only with a general assertion that Bales's testimony would involve C.B.'s "prior consistent statement", with no indication of what particular consistent thing C.B. had said to Bales, the defense attorney's objection probably should have been sustained at that point. However, Bales's free-form description of C.B.'s report was cursory. The significant details of C.B.'s report were elicited when the prosecutor repeatedly asked Bales to describe the particular content of C.B.'s prior statement on points previously raised by the attorneys during the cross-examination and re-direct examination of C.B.
C.B. was the State's first witness. At one point during the direct examination of C.B., the prosecutor refreshed C.B.'s memory by having her read a portion of the transcript of her statement to Detective Bales. However, it was during cross-examination that C.B.'s statement to Detective Bales began to loom large in this case.
The defense attorney's first questions to C.B. were, "Do you recall when you were talked to by Michelle Bales? She had an interview with you back in November. And they taped that [interview], didn't they?" The defense attorney then launched into a cross-examination in which C:B. was repeatedly directed to refer to, and sometimes read aloud, portions of her interview with Bales and her prior testimony to the grand jury. In response to this cross-examination, the prosecutor likewise repeatedly asked C.B. to refer to her statement to Bales in order to refresh her memory during re-direct.
Later in the trial, when Detective Bales was called to testify, her testimony was to a large extent simply a continuation of the process of impeachment and rehabilitation that began when C.B. was on the stand. The prosecutor repeatedly asked Bales about the content of C.B.'s prior statement, but the prosecutor's questions were directed to the particular details that had figured prominently in the cross-examination and re-direct examination of C.B. In fact, the prosecutor's questions were so detailed that Bales could not answer from memory. Again and again-with both attorneys' blessing-Bales was forced to consult the transeript of C.B.'s statement. Indeed, when Bales's answers deviated too much from the transcript of C.B.'s statement, Strumsky's attorney objected and asked the trial judge to direct Bales to read from the transcript rather than paraphrasing or characterizing C.B.'s words.
*507Given these circumstances, Bales's testimony was properly admissible to establish the content of C.B.'s interview on the particular points raised during the cross-examination and re-direct examination of C.B.-not under the theory that Bales was relating C.B.'s "prior consistent statements", but rather because C.B. had been impeached with apparent inconsistencies and omissions in her interview with Bales, and Bales could clarify exactly what C.B. had said or failed to say. In other words, the primary relevance of Bales's testimony was not to assert the truth of C.B.'s prior statements, but rather to establish what those prior statements were.
. See Russell v. State, 934 P.2d 1335, 1344 (Alaska App.1997) (holding that even if the detail offered by a "first complaint" witness exceeded the proper scope of this hearsay exception, "the error was harmless [because the victim] had already testified to all of the details mentioned by [the witness]"). See also Kosbruk v. State, 820 P.2d 1082, 1084 (Alaska App.1991) (noting that "there has been a marked trend toward relaxation of the traditional restrictions governing admission of evidence of the victim's first complaint", and that "[mJore recent decisions have recognized the appropriateness, within the reasonable limits of the trial court's discretion, of allowing details of a first complaint of sexual assault to be admitted for the purpose of enabling the jury to obtain a fair understanding of the circumstances under which the complaint was made").
. See Horton v. State, 758 P.2d 628, 631 (Alaska App.1988) (finding that the arguably inadmissible hearsay accounts of the victims' statements "had little impact on the case" because the adolescent victims "were competent witnesses and that the jury was able to judge their credibility").