State v. Manuel T., 337 Conn. 429

Victim J (age 17) disclosed long‑term sexual abuse by defendant and participated in a recorded forensic interview at a children’s advocacy center observed by law enforcement and a nurse practitioner.
Interview conducted by a nonmedical clinician (Murphy‑Cipolla); video was played at a pretrial hearing and admitted over defendant’s objection under the medical‑diagnosis/treatment hearsay exception.
Defendant sought to introduce two screenshots of text messages that V (defendant’s niece) said came from J, to show motive to fabricate; J denied sending them.
Trial court excluded the screenshots for lack of authentication; jury convicted the defendant of multiple sexual‑assault and risk‑of‑injury counts.
Appellate Court affirmed both evidentiary rulings; Connecticut Supreme Court granted certification, rejected adopting a "primary purpose" rule for the medical‑treatment exception, but concluded the screenshots were improperly excluded and that exclusion was harmful — remanding for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements in a forensic interview are admissible under the medical‑treatment hearsay exception only if the interview’s primary purpose was medical care	State: medical‑treatment exception admits statements reasonably pertinent to diagnosis/treatment; no primary‑purpose requirement	Manuel: forensic interviews are not primarily medical; primary‑purpose test (as in tender‑years/Crawford context) should apply	Court: refused to adopt a primary‑purpose requirement for the medical‑treatment exception; focus remains on declarant’s purpose and pertinence of individual statements
Whether screenshots of text messages were sufficiently authenticated	State: trial court properly excluded because V’s testimony and screenshots lacked date, complete thread, or distinctive identifiers	Manuel: V had personal knowledge (saved contact, received replies matching J), screenshots fairly and accurately reflected messages; prima facie authentication met; exclusion was erroneous and prejudicial	Court: reversed Appellate Court; held V’s testimony met the low prima‑facie authentication standard; exclusion was not harmless and requires a new trial; overruled Eleck to the extent it imposed a heightened authentication rule

State v. Maguire, 310 Conn. 535 (Conn. 2013) (discusses tender‑years exception and testimonial/primary‑purpose analysis)
State v. Griswold, 160 Conn. App. 528 (Conn. App. 2015) (App. Ct. application of medical‑treatment standard to forensic interviews)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause and testimonial statements)
Davis v. Washington, 547 U.S. 813 (U.S. 2006) (primary‑purpose test for testimonial statements)
State v. Mendez, 148 N.M. 761 (N.M. 2010) (rejects applying Crawford/Davis primary‑purpose test to medical‑treatment hearsay)
State v. Kelly, 256 Conn. 23 (Conn. 2001) (statements identifying abuser may be pertinent to diagnosis/treatment)
State v. Dollinger, 20 Conn. App. 530 (Conn. App. 1990) (medical‑treatment exception requires pertinence and desire for treatment)
State v. Eleck, 130 Conn. App. 632 (Conn. App. 2011) (App. Ct. precedent on electronic authentication; overruled in part)
Lorraine v. Markel American Ins. Co., 241 F.R.D. 534 (D. Md. 2007) (principles for authenticating electronic evidence)