State v. Parsons

Summary

The Idaho Supreme Court held that the first recorded CARES interview was testimonial because its primary purpose was to gather evidence about past events for a criminal investigation, not primarily to provide medical care. Because the victim did not testify and the defendant had no prior opportunity to cross-examine her, admitting the interview violated the Confrontation Clause. The court also held that any challenge to the second interview was waived because the defendant did not object to its admission or obtain an adverse ruling on it.