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In the Interest of J.C., Minor Child J.C., Minor Child
Supreme Court of Iowa (2016) | 877 N.W.2d 447; 2016 WL 1273049; 2016 Iowa Sup. LEXIS 41
TL;DR: A four-year-old victim's out-of-court statements to a physician were deemed nontestimonial and admissible under the Confrontation Clause, while similar statements to a forensic interviewer were considered harmless error due to overwhelming independent evidence of guilt.
Legal Significance: Applying Ohio v. Clark, this case holds that a very young child's statements to a physician for medical assessment, without police presence, are nontestimonial and do not violate the Confrontation Clause, even if an investigative purpose exists.