Platt v. State

Appellant Minor Platt, Jr., appeals his conviction following a jury trial for sexual battery of a child while in a position of familial or custodial authority. Appellant argues that the trial court erred in several respects, including by failing to make any factual findings in admitting into evidence the victim’s child hearsay statement. We agree that the trial court reversibly erred in failing to make findings and find that the error was not harmless.1

Appellant was charged with the sexual battery of S.M., who was thirteen at the *777time, while Appellant was in a position of familial or…