State v. Scanlan, 445 P.3d 960

82-year-old victim Leroy Bagnell was found badly bruised and bloodied at home on Nov. 6, 2014; his roommate Theresa Scanlan was later charged with assault, no-contact order violation, unlawful imprisonment, and related offenses.
Bagnell was treated in the ER and in follow-up at Virginia Mason; he gave multiple statements to nurses, physicians, and a social worker about being beaten, restrained, and prevented from contacting family.
Bagnell signed medical-release forms authorizing his providers to release records to police/prosecutors; he did not testify at trial.
The trial court admitted Bagnell’s out-of-court statements to medical providers; the jury convicted Scanlan of second-degree assault, unlawful imprisonment, and a no-contact-order violation (later reduced on appeal).
On appeal Scanlan argued the medical statements were testimonial (violating the Sixth Amendment confrontation clause) and that there was insufficient evidence for unlawful imprisonment.
The Washington Supreme Court considered whether the primary-purpose test governs statements to nongovernmental witnesses and whether the record supports the unlawful imprisonment conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Scanlan)	Held
Whether Bagnell’s statements to medical providers were "testimonial" under the Confrontation Clause	Statements were nontestimonial because they were made to obtain medical treatment and to address an ongoing emergency	Statements were testimonial (medical releases and later follow-ups showed expectation of use at trial); admission violated Sixth Amendment	Statements were nontestimonial under the primary-purpose test and their admission did not violate the Confrontation Clause
Whether there was sufficient evidence to support unlawful imprisonment conviction	Victim’s statements plus circumstantial evidence (blocked phones, damaged house, weapons, victim’s stupor) support knowing restraint beyond consent	Defense argued multiple escape routes and claimed insufficiency	Conviction affirmed; evidence (direct and circumstantial) was sufficient for a rational trier of fact to find unlawful imprisonment

Crawford v. Washington, 541 U.S. 36 (admission of testimonial hearsay violates Confrontation Clause unless witness unavailable and defendant had prior opportunity for cross-examination)
Davis v. Washington, 547 U.S. 813 (announcing primary-purpose test for ongoing-emergency vs. statements aimed at proving past events)
Michigan v. Bryant, 562 U.S. 344 (primary-purpose inquiry is objective and considers statements/actions of declarant and interrogators)
Ohio v. Clark, 135 S. Ct. 2173 (statements to nongovernmental actors less likely to be testimonial; primary-purpose test applies to teachers in child-abuse context)
Giles v. California, 554 U.S. 353 (observations that statements to physicians for treatment are generally non‑testimonial)
Melendez‑Diaz v. Massachusetts, 557 U.S. 305 (distinguishing forensic reports from medical treatment records as testimonial in some contexts)
Bullcoming v. New Mexico, 564 U.S. 647 (distinguishing testimonial forensic reports from non‑testimonial medical records)