State v. Carol M.D.

Schultheis, A.C.J.

ER 803(a)(4) excepts from the hearsay rule “[s]tatements made for purposes of medical diagnosis or treatment. . . .” The admission of such statements at trial does not violate the Confrontation Clause because their reliability is insured by the declarant’s self-interest in providing accurate information to obtain effective medical treatment. In this case, we are asked to decide whether the trial court properly admitted under ER 803(a)(4) statements made by a child to her counselor describing sexual abuse by her parents. We conclude the court admitted those statements without…