State v. Robinson (2006)

Supreme Court of Minnesota · 2006 · Evidence

718 N.W.2d 400 (Minn. 2006)

Updated August 22, 2026

EvidenceHearsayMedical diagnosis and treatmentResidual hearsay exceptionPrior identificationMinn. R. Evid. 803(4)Minn. R. Evid. 803(24)Minn. R. Evid. 801(d)(1)(C)

Facts

After seeking hospital treatment for an eye injury, F.T. told two nurses that Robinson, the father of her children and former boyfriend, had hit or slapped her. Before trial, however, F.T. changed her account and testified that her injury occurred accidentally when Robinson pushed open a bathroom door and it struck her eye. The district court admitted her statements to the nurses substantively under Minn. R. Evid. 803(4). Medical testimony at trial indicated that the injury could not have been caused by the edge of a door.

Issue

Whether the victim's out-of-court statements to treating nurses identifying Robinson as the person who caused her injury were admissible under the medical diagnosis and treatment exception, and if not, whether their admission was nonetheless harmless because the statements were admissible under another hearsay theory.

Rule

Under Minn. R. Evid. 803(4), statements describing the cause or external source of an injury are admissible only insofar as reasonably pertinent to diagnosis or treatment; statements attributing fault, including identifying the perpetrator, are ordinarily not admissible absent an evidentiary foundation showing that identity was reasonably pertinent to diagnosis or treatment in the particular case. Under Minn. R. Evid. 801(d)(1)(C), a prior identification does not include an out-of-court accusation against an offender whose identity was already well known to the victim. Under Minn. R. Evid. 803(24), admissibility turns on the totality of the circumstances showing equivalent guarantees of trustworthiness, and corroborating evidence may be considered where the declarant testifies and is subject to cross-examination.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Milwaukee, Tessa Nolan arrived at an urgent care clinic with a fractured cheekbone. She told the triage nurse, without prompting, that "my ex, Darren Pike, punched me," and the nurse used the statement only to record how the injury occurred before treatment. At trial, Tessa testifies that she actually fell into a countertop and that she named Darren only because she was angry with him.

Is Tessa's statement identifying Darren admissible substantively under the medical diagnosis or treatment exception?

Explanation. The majority held that statements describing the cause or external source of an injury may be admitted under the medical diagnosis exception, but statements attributing fault, including identifying the perpetrator, are ordinarily not admissible unless the record establishes that identity was reasonably pertinent to diagnosis or treatment in the particular case. Here, the fact pattern gives no foundation that Darren's identity mattered to treatment, so the identity portion is not admissible under that exception.