State v. Nelson
State v. Nelson, 725 P.2d 1353, 1356 n.3 (Utah 1986) is the principal case on Utah Code Ann. 76-5-411 (1999).
There, the defendant was convicted of the rape and aggravated sexual abuse of a child. Nelson, 725 P.2d at 1353.
Raising the issue of section 76-5-411's reliability findings sua sponte, we recommended the "consideration of . . . matters not specifically mentioned in the statute." Id. at 1356 n.3.
The opinion held only that "the trial court must make an in-depth evaluation of the proposed testimony"; it did not require that those findings be written. Id.