People v. Meeboer

In People v. Meeboer (After Remand), 439 Mich 310, 322; 484 NW2d 621 (1992), the Supreme Court of Michigan adopted a ten-factor test for establishing the trustworthiness of a young declarant's statement in recognition that complainants of "tender years" may not have the same understanding of the need to tell the truth to medical professionals that adults do. Id. at 323. No single factor is dispositive of the issue of trustworthiness. A reviewing court should consider these ten factors under the totality of the circumstances to determine whether the trial court abused its discretion in rendering the evidentiary ruling under review.