Reliability of a Child's Statements In Georgia

In Gregg v. State, 201 Ga. App. 238 (411 SE2d 65) (1991), the Court set forth certain factors the trial court may consider in determining the reliability of a child's statements: (1) the atmosphere and circumstances under which the statement was made (including the time, the place, and the people present thereat); (2) the spontaneity of the child's statement to the persons present; (3) the child's age; (4) the child's general demeanor; (5) the child's condition (physical or emotional); (6) the presence or absence of threats or promise of benefits; (7) the presence or absence of drugs or alcohol; (8) the child's general credibility; (9) the presence or absence of any coaching by parents or other third parties before or at the time of the child's statement, and the type of coaching and circumstances surrounding the same; and the nature of the child's statement and type of language used therein; (10) the consistency between repeated out-of-court statements by the child. Id. at 240-241 (3) (b).