State v. Giovanni D.

Summary

The court held that statements made by a child during a forensic interview qualify under the medical-treatment hearsay exception only when the child was motivated at least in part to obtain medical diagnosis or treatment and the statements were reasonably pertinent to that purpose. Although the trial court improperly admitted portions of the child's forensic-interview statements, the error was harmless because the testimony was largely cumulative and was not materially emphasized in closing argument. The court also upheld the denial of a special child-credibility instruction and declined to alter its existing discretionary approach. No separate opinions were filed.