State v. Manuel T.
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The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of six counts of sexual assault and four counts of risk of injury to a child from the sexual abuse of his girlfriend's daughter, J, holding that the trial court erred in excluding screenshot photographs of text messages purportedly sent by J to Defendant's niece.
Specifically, the Supreme Court held (1) the appellate court correctly upheld the admission into evidence of a video recording of a forensic interview of J by a nonmedical professional under the medical diagnosis and treatment exception to the hearsay rule; but (2) the appellate court incorrectly concluded that the trial court had properly excluded J's text messages on the ground that they had not been sufficiently authenticated, and the improper exclusion of the text messages requires reversal of the judgment and a new trial.
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