State v. Slater, 285 Conn. 162

Summary

The Supreme Court of Connecticut affirmed the defendant's convictions for first-degree sexual assault and first-degree kidnapping. The court held that the victim's statements to civilian bystanders and medical personnel were nontestimonial under the Sixth Amendment and were properly admitted under Connecticut hearsay exceptions. It also concluded that the trial court's failure to give a specific instruction concerning the jailhouse informant's potential bias was harmless error.

Holdings

1. The victim's statements to the civilian bystanders were nontestimonial because, viewed objectively and in context, they were an informal cry for help rather than a solemn declaration made to establish past events for later prosecution. The Confrontation Clause therefore did not bar their admission.
2. The trial court properly admitted the statements under the spontaneous-utterance exception to the hearsay rule.
3. The victim's statements to the nurse and physician were nontestimonial because their primary purpose was medical diagnosis and treatment, notwithstanding the simultaneous administration of a rape kit for forensic evidence.
4. The statements to the nurse and physician were properly admitted under the medical-treatment exception because they were made in furtherance of medical treatment and described injuries or conditions pertinent to treatment.
5. Although the trial court improperly failed to give the requested specific instruction concerning the informant's possible motive and hope for leniency, the error was harmless and did not warrant reversal.

Questions Presented

1. Whether the victim's statements to civilian bystanders were testimonial under the Sixth Amendment's Confrontation Clause and Crawford v. Washington.
2. Whether the victim's statements to medical personnel during treatment and rape-kit administration were testimonial under the Confrontation Clause.
3. Whether the trial court's failure to give a specific instruction concerning the jailhouse informant's possible motive, bias, and hope for leniency was harmful error.

Disposition

affirmed