State v. Aguallo

Chief Justice BILLINGS

dissenting in part.

Although N.C.G.S. § 8C-1, Rule 803(4) was clearly intended to liberalize the hearsay exception allowing introduction for substantive use of statements made for purposes of medical diagnosis or treatment, the rule must not be applied mechanically, without regard for its intent and justification.

The benchmark for use of hearsay testimony is an identifiable reason for recognizing that the statement made by a declarant out of court and not under oath is inherently reliable. That inherent reliability may be found in the self-interest of a person seeking medical treatment. The patient, seeking help for his or her medical condition, realizes that in order for the physician to make an accurate diagnosis and to provide effective treatment, the information regarding the onset of symptoms, the location and kind of pain, etc. must be accurately related. State v. Smith, 315 N.C. 76, 337 S.E. 2d 833 (1985). The information is inherently reliable only if the speaker realizes the necessity for the information to be correct.

In the majority opinion, the focus seems to be placed, not upon the realization by the child that accurate identification of her abuser was necessary to her treatment, but upon the doctor’s knowledge of why information, usually “irrelevant to an anticipated course of treatment,” (318 N.C. 590, 597, 350 S.E. 2d 76, 80) and “ordinarily . . . not properly covered by the Rule 803(4) exception to the hearsay rule,” (id.) is useful for the treatment of the sexually abused child.

In the case sub judice, nothing in the majority opinion indicates that the child sought medical treatment or was aware that her truthful identification of her abuser was necessary in aid of treatment. The visit to the physician’s office was prompted not by the child’s seeking either physical or psychological help necessitated by an act that occurred seven months earlier, but by adults’ reaction to information that a criminal act had taken place. Instead of adopting a mechanical rule that so long as the recipient *601of an out of court declaration has a medical degree, the statement of a patient is admissible at trial if the physician is aware of some diagnosis or treatment use which he or she can make of the information, I would require at least some basis upon which to infer that the declarant was aware of the heightened need for truthfulness. If, as I suspect, the basis for the majority’s faith in the reliability of the statement has more to do with the age of the victim than it does with her realization of the need for truthfulness in order to get appropriate treatment, this Court should encourage the legislature to consider the appropriateness of special rules for obtaining evidence in child sexual abuse cases1 rather than to try to fit this testimony into a mold which cannot contain it. As at least one commentator has observed, “Concern over the recent revelations of child sex abuse have [sic] caused several state *602courts to expand, if not distort, the concept of diagnosis or treatment.” M. Graham, Handbook of Federal Evidence § 803.4 at 828 n. 4 (2d ed. 1986).

In the case sub judice the hearsay declarant also testified at trial and was subject to confrontation and cross-examination by the defendant; therefore substantive use of the hearsay evidence does not raise questions about violation of the defendant’s rights under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The majority opinion appropriately does not deal with the Confrontation Clause problem since it was not raised. However, I fear that this case may encourage prosecutors to rely exclusively upon the testimony of physicians, relating hearsay statements of child victims in sex abuse cases, to identify the abusers. I therefore dissent from the holding that the statement of the child to the witness was admissible as substantive evidence, and I also write to suggest that prosecutors exercise caution in relying exclusively on hearsay statements to prove the offense in cases of child sexual abuse.

. See Unif. R. Evid. Rule 807 (1986). The American Bar Association approved Guidelines for the Fair Treatment of Child Witnesses in Cases Where Child Abuse Is Alleged at its 10 July 1985 meeting. The guidelines recommend allowance of videotaped depositions as follows:

3. In criminal cases and juvenile delinquency and child protection proceedings where child abuse is alleged, court procedures and protocol should be modified as necessary to accommodate the needs of child witnesses including:

j) When necessary the court should permit the child’s testimony at a pretrial or noncriminal hearing to be given by means of a videotaped deposition.

American Bar Association, Guidelines for the Fair Treatment of Child Witnesses in Cases Where Child Abuse Is Alleged 1-2 (1985). In North Carolina the Governor’s Crime Commission recommended “that the General Assembly enact legislation to allow for the electronic transmission or recording of child victim testimony which protects the defendant’s right to confront the witnesses against him or her” and drafted a proposed act. Governor’s Crime Commission, Department of Crime Control and Public Safety, Missing Children: A Report to the Governor 6-9 (1985).

For discussions of the problem and references to legislation adopted by various states see R. Eatman & J. Bulkley, Protecting Child Victim/Witnesses: Sample Laws and Materials 17-34 (National Legal Resource Center for Child Advocacy & Protection 1986); National Legal Resource Center for Child Advocacy and Protection-Child Sexual Abuse Law Reform Project, Evidentiary and Procedural Trends in State Legislation and Other Emerging Legal Issues in Child Sexual Abuse Cases 11-12, 26-27 (American Bar Association, Young Lawyers Division 1985); Selected State Legislation: A Guide for Effective State Laws to Protect Children 20-21 (National Center for Missing & Exploited Children 1985); D. Whitcomb, E. Shapiro & L. Stellwagen, When the Victim Is a Child 59-68 (U.S. Department of Justice, National Institute of Justice 1985).