Cole v. State
In Cole v. State (Ark. 1991) 307 Ark. 41, 818 S.W.2d 573, the mentally retarded victim's statement fit within the state's hearsay exception.
The court noted that the 23-year-old witness had the mental capacity of a six or seven-year-old child, and applied the same rationale it would apply in a case involving a young child. (Id. at pp. 575-576.)
The court considered the circumstances surrounding the victim's statements and determined that to the extent the statements fit within the hearsay exception they were admissible. (Id. at p. 576.) Only when the statement failed to satisfy the requirements of the exception did the court rule the statement inadmissible.