State v. Maldonado

In State v. Maldonado, 13 Conn. App. 368, 371, 536 A.2d 600, cert. denied, 207 Conn. 808, 541 A.2d 1239 (1988), the Court concluded that "in cases of sexual abuse in the home, hearsay statements made in the course of medical treatment which reveal the identity of the abuser, are reasonably pertinent to treatment and are admissible." Id., 374. The fact that in that case the victim's nonverbal communications were made to a security guard, acting as an interpreter, and not directly to the treating physician, nor even in his presence, was of no consequence. The Court recognized in Maldonado that neither the state nor the defendant addressed this issue in their briefs; we also noted that the comments of the advisory committee on the Federal Rules of Evidence provides that to be admissible under this exception the statement need not have been made to a physician and that statements to hospital attendants, ambulance drivers or even members of the family ought to be included. State v. Maldonado, supra, 13 Conn. App. 374 n.3.