Llanos v. State

We reverse Appellant’s convictions and sentences for armed kidnapping and aggravated battery. The trial court erred in admitting a medical report containing inadmissible hearsay.

At trial, Appellant moved in limine to exclude the medical record prepared by the victim’s physician. In it, the doctor stated, “[Patient] has had domestic abuse with a boyfriend ...” and “I read the police report and this has also been documented relative to domestic abuse.”

The trial court admitted the “medical” statements under section 90.803(4), Florida Statutes, which provides for the admission of:

Statements made…