State v. Hill, 236 Ariz. 162

Victim (pregnant teenage girl) was sexually assaulted in 2001; taken to an ER in premature labor where a forensic nurse (SANE) examined her and collected a rape kit.
The nurse asked an open-ended question ("Tell me why you're here") and the victim gave a graphic account of the assaults; the nurse recorded this on a Sexual Assault Examination Report.
DNA from the rape kit later tied evidence from the scene to Odece Hill, who was arrested ten years after the assault; the victim died before trial.
At trial the State sought to admit the nurse’s recounting of the victim’s statement; Hill objected under the Sixth Amendment Confrontation Clause because the declarant did not testify and could not be cross-examined.
The superior court admitted the statement; Hill was convicted on multiple counts and appealed, arguing the nurse’s testimony was testimonial hearsay in violation of Crawford and its progeny.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether victim’s statement to a forensic nurse was "testimonial" under the Sixth Amendment	State: statement was non-testimonial because it was made during a medical exam to obtain diagnosis/treatment	Hill: statement was testimonial because the nurse was a forensic examiner collecting evidence and the statement functioned as prosecution evidence	The statement was non-testimonial; admission did not violate the Confrontation Clause

Crawford v. Washington, 541 U.S. 36 (sets the testimonial framework for Confrontation Clause analysis)
Davis v. Washington, 547 U.S. 813 (distinguishes testimonial versus nontestimonial statements based on primary purpose and ongoing emergency)
Michigan v. Bryant, 562 U.S. 344 (clarifies objective, totality-of-circumstances primary-purpose test)
Hartsfield v. Commonwealth, 277 S.W.3d 239 (Ky. 2009) (SANE interview found testimonial where primary purpose was investigation)
State v. Tucker, 215 Ariz. 298 (Ariz. Ct. App.) (standard of review for Confrontation Clause issues)