context: As the trial court found, the statement was made in a hospital -- "the most formal of medical settings" -- after the victim had undergone "diagnostic tests up to and including a CAT scan." In addition, the victim had an existing doctor-patient relationship with Gladstone as she had met with her in Gladstone's medical office on two prior occasions in the previous six months.
citation_a.signal: cf.
citation_a.identifier: 986 N.E.2d 255, 265
citation_a.parenthetical: holding that there was insufficient evidence that alleged victim made statements to forensic nurse-examiner for purpose of medical diagnosis or treatment in part because there was no evidence regarding alleged victim's "past experience with medical facilities or medical providers"
citation_a.sentence: See State v. Graf, 143 N.H. 294, 304 (1999) (noting preexisting relationship between doctor and victim in analysis of whether victim made statements for purpose of medical diagnosis or treatment); cf. VanPatten v. State, 986 N.E.2d 255, 265 (Ind. 2013) (holding that there was insufficient evidence that alleged victim made statements to forensic nurse-examiner for purpose of medical diagnosis or treatment in part because there was no evidence regarding alleged victim’s “past experience with medical facilities or medical providers”).
citation_b.signal: see
citation_b.identifier: 143 N.H. 294, 304
citation_b.parenthetical: noting preexisting relationship between doctor and victim in analysis of whether victim made statements for purpose of medical diagnosis or treatment
citation_b.sentence: See State v. Graf, 143 N.H. 294, 304 (1999) (noting preexisting relationship between doctor and victim in analysis of whether victim made statements for purpose of medical diagnosis or treatment); cf. VanPatten v. State, 986 N.E.2d 255, 265 (Ind. 2013) (holding that there was insufficient evidence that alleged victim made statements to forensic nurse-examiner for purpose of medical diagnosis or treatment in part because there was no evidence regarding alleged victim’s “past experience with medical facilities or medical providers”).