State v. Christensen, 458 P.3d 951

Two 13-year-old twin sisters (A.M.O. and A.G.O., functioning at a third-grade level) reported sexual touching by their step-grandfather, David Lee Christensen; school officials referred them to St. Luke’s CARES for evaluation.
CARES protocol included a forensic interview (NICHD-guided), a psychosocial assessment, and a medical exam; interviews inform the subsequent medical examination.
Lara Foster (medical social worker) conducted forensic interviews in June 2017; both twins disclosed inappropriate touching and physical symptoms (pain, bleeding).
Christensen was indicted on five counts of lewd conduct; the State sought to admit the CARES interviews under I.R.E. 803(4) (statements for medical diagnosis/treatment).
The district court ruled the interviews admissible under I.R.E. 803(4); the interviews were received by stipulation at trial, both twins testified, and a jury convicted Christensen on four counts.
On appeal Christensen argued (1) the court abused its discretion in admitting the interviews under Rule 803(4) and (2) the court should have redacted introductory/rapport-building/episodic-memory portions; the Supreme Court affirmed.

Issue	State's Argument	Christensen's Argument	Held
Admissibility under I.R.E. 803(4) (medical-diagnosis exception)	Interviews were made for medical diagnosis/treatment and were reasonably pertinent; CARES interviews inform medical exams.	Twins did not necessarily understand statements were for medical/diagnostic purposes; court failed to assess their appreciation of that purpose.	Affirmed — totality of circumstances (per State v. Kay) shows statements were made for medical diagnosis/treatment and the district court did not abuse its discretion.
Whether preliminary/rapport/episodic-memory portions should have been redacted prior to admission	Those portions are either not offered for truth (context only) or were pertinent to diagnosis; objection not sufficiently particularized.	Early-phase questions are not pertinent to medical diagnosis and should have been redacted.	Affirmed — statements provided context and were not hearsay as offered; appellant failed to preserve/particularize redaction objections.

State v. Kay, 129 Idaho 507, 927 P.2d 897 (Ct. App. 1996) (adopts totality-of-circumstances test for pediatric statements under medical-diagnosis exception)
State v. Nelson, 131 Idaho 210, 953 P.2d 650 (Ct. App. 1998) (child’s ER statements admissible under medical exception)
State v. Stanfield, 158 Idaho 327, 347 P.3d 175 (2015) (trial court’s discretion in hearsay exception rulings)
White v. Illinois, 502 U.S. 346 (1992) (medical-treatment context provides guarantees of trustworthiness for hearsay exceptions)
Webster v. State, 827 A.2d 910 (Md. Ct. App. 2003) (forensic/medical interviews with dual purpose can fit medical exception)
State v. Hill, 161 Idaho 444, 387 P.3d 112 (2016) (definition of hearsay and admissibility principles)