State v. Matsamas
In State v. Matsamas, 808 P.2d 1048 (Utah 1991), the defendant was convicted of rape and sodomy of a child. Id. at 1049.
The trial court admitted the evidence was based solely on the conclusion that "it might help the jury and the court decide what had occurred." Id. at 1052.
No specific findings were made. The Court reversed, finding that the convictions were based in part on the evidence admitted under Utah Code Ann. 76-5-411 (1999), and that the trial court had failed to make the necessary findings regarding reliability of the evidence. Id.
In Matsamas, the Court did not mention a writing requirement.