State v. Parsons

Summary

The Idaho Supreme Court held that the first recorded CARES interview was testimonial because its primary purpose, viewed objectively, was to develop evidence for a criminal investigation rather than provide medical care. Because Parsons had no prior opportunity to cross-examine the child, admitting the interview violated the Confrontation Clause; the court also held that any challenge to the second interview was waived. The judgment of conviction was vacated and the case remanded for further proceedings.