noting, in Confrontation Clause analysis, child interview with Dr. Harre was not primarily for testimonial purposes but for medical treatment and citing similar testimony
How later courts described this case
- noting, in Confrontation Clause analysis, child interview with Dr. Harre was not primarily for testimonial purposes but for medical treatment and citing similar testimony
- “[W]e do not believe admission of [a physician’s] testimony and report [containing out-of-court- statements of a child] violated [a delinquent’s] rights of confrontation under the Sixth Amendment [or article I, section 10 of the Iowa Constitution].”
- noting very young children may not be competent to testify
- noting absence of eyewitnesses in many child-abuse cases
Written by the judges who cited it.
The opinion
CADY, Chief Justice
(concurring specially).
I join in the opinion of the majority, but would not place weight on the eighteenth century practice of - admitting statements of very young children. I otherwise agree the totality of the circumstances supports the conclusion that the primary purpose of the interview by Dr. Harre was not testimonial. •