Supreme Court of Rhode Island
State v. Eugene Pina
January 27, 19831983 R.I. LEXIS 792
Summary
The court held that a treating physician's testimony repeating the complainant's statements about threats, coercion, and the defendant's intent was inadmissible hearsay because those statements were not pertinent to diagnosis or treatment and primarily assigned fault. It further held that admitting the testimony was highly prejudicial because the physician's status could improperly bolster the complainant's credibility. The conviction was vacated and the case was remanded for further proceedings.
Holding
- Admissibility of the physician's testimony under the medical-diagnosis exception. Statements made by the complainant to the treating physician that described threats, coercion, and the defendant's culpability were inadmissible hearsay because they were not helpful to diagnosis or treatment and instead addressed the disputed issue of consent and assigned fault.
- Prejudice resulting from admission of the physician's testimony. Admission of the physician's repetition of the complainant's version of events was highly prejudicial because the physician's status as a medical expert was likely to lend credibility to the complainant's account and improperly influence the jury.
Docket 81-525-C.A.