484, 488; 596 NW2d 607 (1999). 17 MRE 801(c). 18 MRE 802 (“Hearsay is not admissible except as provided by these rules.”). 19 MRE 803A (emphasis added). 20 This Court first recognized the common-law tender years rule in People v Gage, 62 Mich 271; 28 NW 835 (1886), as a permissible rule to allow hearsay in order to corroborate the testimony of a child complainant. “The rule in this State is that where the victim is of tender years the testimony of the details of her complaint may be introduced in corroboration of her evidence, if her statement is shown to have been spontaneous and without indication of manufacture; and delay in making the complaint is excusable so far as it is caused by fear or other equally effective circumstance.” People v Baker, 251 Mich 322, 326; 232 NW 381 (1930) (<HOLDING>). However, this Court held in People v Kreiner,
holding that because the record in the case had not been developed sufficiently to determine whether a childs statement was admissible under the tender years exception a new trial was warranted holding that only selfinculpatory aspects of hearsay statement but not other parts of statement are admissible under exception for statements against penal interest holding also that only a childs first statement made is admissible under the exception holding that videotape was admissible under rule 801e1b as prior consistent statement because defense challenged childs credibility holding multiple statements by childvictim and childs mother admissible under residual exception