State of Iowa v. Trent D. Smith, 2016 Iowa Sup. LEXIS 26

On June 9, 2012, MD called 911 reporting threats from Trent Smith; MD identified the assailant as Smith to officers.
MD was treated at a hospital ER where a nurse and doctor asked questions about injuries and domestic violence, and MD identified Smith as her attacker.
The district court admitted MD’s statements identifying Smith to medical personnel under Iowa Rule of Evidence 5.803(4) (medical diagnosis or treatment).
MD later recanted her identification at trial; the State planned to prove identity through MD’s statements to officers and medical personnel.
The court of appeals affirmed admission of the nurse/doctor statements under 5.803(4) but reversed as to police testimony; the Supreme Court agreed to review.
The Supreme Court held there was insufficient foundation to admit the nurse/doctor identity statements under 5.803(4), reversed the district court, and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MD’s identity statements to medical personnel are admissible under 5.803(4).	Smith argues such identity statements lack foundation for medical treatment.	Smith contends the statements were not reasonably pertinent to diagnosis or treatment.	No; insufficient foundation under 5.803(4); remanded for new trial.

State v. Tracy, 482 N.W.2d 675 (Iowa 1992) (adopted two-part test for admissibility of identity statements in medical context)
State v. Hildreth, 582 N.W.2d 167 (Iowa 1998) (recognizes identity of abuser may assist in diagnosis/treatment in emotional injuries)
United States v. Renville, 779 F.2d 430 (8th Cir.1985) (two-part test for medical diagnosis/treatment exception)
State v. Tomquist, 600 N.W.2d 301 (Iowa 1999) (child-abuse context for 5.803(4) admissibility; treatment-focused)
State v. DeVoss, 648 N.W.2d 56 (Iowa 2002) (recognizes discretionary use of alternative grounds for admissibility)