State v. Goings, 2012 Ohio 1793

Goings was indicted for one count of gross sexual imposition involving four-year-old K.S.
Goings moved in limine to suppress an interview between K.S. and Logan County Children’s Services social worker Erica James as testimonial.
The interview occurred Aug. 6, 2010 at the Children’s Services facility to assess veracity of allegations and need for medical or emotional treatment.
During the interview, K.S. described touching by Goings; James used dolls and identified body parts; Goings’ name was repeatedly introduced by James.
James did not forward interview findings to medical professionals and did not report to medical authorities; instead, she alerted the police after concluding the interview.
The trial court granted the motion in limine suppressing the entire interview; the State appealed, arguing some portions were for medical diagnosis or treatment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements to the social worker were for medical diagnosis or treatment	Goings—State argues some statements were for medical diagnosis/treatment.	Goings—Appellee contends statements were investigatory, not medical.	Assignment overruled; statements not for medical diagnosis; judgment affirmed

State v. Arnold, 126 Ohio St.3d 290 (2010-Ohio-2742) (dual-purpose social-worker interview; distinguishes testimonial vs. medical-diagnosis statements)
State v. Muttart, 116 Ohio St.3d 5 (2007-Ohio-5267) (nonexhaustive factors for determining medical-diagnosis purpose)
State v. Dudli, 2006-Ohio-601 (3d Dist. No. 3-05-13) (mixed questions of law and fact in suppress rulings; appellate review standard)
State v. Dever, 64 Ohio St.3d 401 (1992) (context of medical significance influencing child-victim statements)