State of Minnesota, Respondent v. Andre Robinson, Appellant (Minnesota 2006)

Summary

The court held that the victim's identification of Robinson as the assailant was not admissible under the medical-diagnosis hearsay exception because the record lacked an adequate foundation that the assailant's identity was pertinent to treatment. The identification was also not admissible as a prior identification of an unknown offender, but it was admissible under the residual hearsay exception based on the totality of circumstances, including its consistency and corroboration. The medical-diagnosis ruling was therefore harmless, and the conviction was affirmed. Chief Justice Anderson, joined by Justice Meyer, would have upheld admission under the medical-diagnosis exception, while Justice Page concurred in the result.

Holding

Medical-diagnosis and treatment hearsay exception. A domestic-abuse victim's identification of the person who caused an injury is not admissible under the medical-diagnosis and treatment exception when the record lacks sufficient evidence that the person's identity was reasonably pertinent to diagnosis or treatment. The victim's description of the mechanism of injury, however, was admissible because it concerned the cause or external source of the injury.

Prior-identification rule. The prior-identification rule does not apply to an out-of-court accusation against an offender whose identity was already known to the victim.

Residual hearsay exception and harmless error. F.T.'s statements identifying Robinson were admissible under the residual hearsay exception, and the district court's erroneous admission of them under the medical-diagnosis exception was harmless because there was no reasonable possibility that the error significantly affected the verdict.

State of Minnesota, Respondent v. Andre Robinson, Appellant

Summary

Holding

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