State v. Giovanni D.

Summary

The court held that statements made during a child’s forensic interview qualify for the medical-treatment hearsay exception only when the child was motivated at least partly by a desire for medical diagnosis or treatment and the statements were pertinent to that objective. Although the trial court improperly admitted portions of the interview through the forensic interviewer, the error did not substantially affect the verdict because the evidence was largely cumulative and was not emphasized in closing argument. The court also upheld the denial of a special child-credibility instruction and declined to alter the governing discretionary approach.