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5 Washington opinions name it 1 courts 1994–2025 2 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Fishergreen2 sentences2005In State v. Fisher, ___ Wash.App. ___, 108 P.3d 1262, 1269 (2005), the court held that the statement made by a victim of child abuse to a physician was not testimonial. 2005In State v. Fisher, 130 Wn. | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Sims
green
2 sentences2005State v. Sims, 77 Wash.App. 236, 239-240 , 890 P.2d 521 (1995) (Victim's statements to ER doctor and social worker were admissible where victim identified her boyfriend as the person who broke her jaw.). ¶ 20 Courts that have addressed Crawford's impact on statements admitted under the medical diagnosis and treatment exception focus on the purpose of the declarant's encounter with the health care provider. 2005App. 236, 239-40 , 890 P.2d 521 (1995) (victim’s statements to ER doctor and social worker were admissible where victim identified her boyfriend as the person who broke her jaw). ¶20 Courts that have addressed Crawford’s impact on statements admitted under the medical diagnosis and treatment exception focus on the purpose of the declarant’s encounter with the health care provider. | 2 | 2005–2005 |
State v. Burke
green
2 sentences2025ER 803(a)(4) provides that a statement is excepted from the hearsay rule where it was “made for purposes of medical diagnosis or treatment and describing medical history, or past or present symptoms, pain, or sensations, or the inception or general character of the cause or external source thereof insofar as reasonably pertinent to diagnosis or treatment.” The “test for statements made for medical diagnosis or treatments considers the subjective purposes of both the declarant and the medical professional.” State v. Burke, 196 Wn.2d 712, 740 , 478 P.3d 1096 (2021). 2025ER 803(a)(4) provides that a statement is excepted from the hearsay rule where it was “made for purposes of medical diagnosis or treatment and describing medical history, or past or present symptoms, pain, or sensations, or the inception or general character of the cause or external source thereof insofar as reasonably pertinent to diagnosis or treatment.” The “test for statements made for medical diagnosis or treatments considers the subjective purposes of both the declarant and the medical professional.” State v. Burke, 196 Wn.2d 712, 740 , 478 P.3d 1096 (2021). | 1 | 2025–2025 |
State v. Woods
red
1 sentence2021Woods, 143 Wn.2d at 602 . 16 In State v. Urbina, the court held that statements about being thrown down, raped, threatened, and using mace were all admissible as reasonably pertinent for diagnosis and treatment of physical and psychological injuries. | 1 | 2021–2021 |
Frye v. United States
red
2 sentences1994She also contends the trial court erred by admitting expert testimony about posttraumatic stress syndrome because the witness was not qualified as an expert, the evidence did not satisfy the reliability requirements of Frye v. United States, 293 F. 1013, 1014 , 34 A.L.R. 145 (D.C. 1994She also contends the trial court erred by admitting expert testimony about posttraumatic stress syndrome because the witness was not qualified as an expert, the evidence did not satisfy the reliability requirements of Frye v. United States, 293 F. 1013, 1014 , 34 A.L.R. 145 (D.C. | 1 | 1994–1994 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.