Oldman v. State
2000 Wyo. LEXIS 46, 998 P.2d 957, 2000 WL 256104 (2000)
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Rule of Law:
A victim's out-of-court statement to a physician identifying a domestic abuser is admissible under the hearsay exception for statements made for medical diagnosis or treatment because the abuser's identity is reasonably pertinent to the victim's proper emotional, psychological, and preventative care.
Facts:
- Steven Charles Oldman and the victim had lived together in a relationship akin to marriage for ten to twelve years and had four children together.
- The victim was six months pregnant with their fifth child.
- On the morning of April 3, 1995, a neighbor heard a male yelling in the victim's apartment, followed by the sound of a woman crying.
- The neighbor saw a man with a build and hair color similar to Oldman's walking away from the apartment shortly after.
- The victim appeared at the police station badly beaten, bleeding, crying, and hysterical.
- The victim was taken to a hospital emergency room, where the attending physician noted a black eye, facial bruising, and numerous human bite marks on her body.
- Without being prompted by the physician, the victim stated that her husband had beaten and bitten her.
Procedural Posture:
- Steven Oldman was charged in a Wyoming district court with aggravated assault upon a pregnant woman.
- The case proceeded to a jury trial where the victim did not appear to testify.
- The prosecution called the emergency room physician to testify about statements the victim made identifying Oldman as her attacker.
- Oldman's counsel objected to the physician's testimony as inadmissible hearsay.
- The trial court overruled the objection and admitted the testimony under the medical diagnosis or treatment exception (W.R.E. 803(4)).
- During jury selection, Oldman's counsel moved for a mistrial after a prospective juror stated he believed Oldman was guilty; the court denied the motion.
- The jury found Oldman guilty of the charge.
- The district court entered a Judgment and Sentence, ordering imprisonment for seven to ten years.
- Oldman (as appellant) appealed his conviction and sentence to the Supreme Court of Wyoming, with the State of Wyoming as appellee.
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Issue:
Does the hearsay exception for statements made for the purpose of medical diagnosis or treatment (W.R.E. 803(4)) permit an emergency room physician to testify about a domestic violence victim's statement identifying her attacker?
Opinions:
Majority - Thomas, Justice
Yes, the hearsay exception for statements made for medical diagnosis or treatment permits a physician's testimony about a domestic violence victim's statement identifying her attacker. The court held that the statements were admissible under both W.R.E. 803(4) (statements for medical diagnosis/treatment) and W.R.E. 803(2) (excited utterance). Applying a two-part test for the medical diagnosis exception, the court found the victim's motive was to promote treatment and the content was reasonably relied upon by the physician. It extended the rationale from child and sexual abuse cases, reasoning that in domestic abuse, the abuser's identity is 'reasonably pertinent' to treatment because it allows the physician to address emotional and psychological injuries and take steps to protect the victim from further harm. The court also found the statements qualified as an excited utterance because the victim was still under the stress of a 'savage beating' and was described as 'distraught and hysterical,' making her statements spontaneous rather than fabricated.
Analysis:
This decision significantly broadens the application of the medical diagnosis and treatment hearsay exception (W.R.E. 803(4)) in the context of domestic violence. By extending the logic previously applied to child abuse cases—where an abuser's identity is crucial for psychological treatment—to adult domestic abuse, the court acknowledges the unique dynamics of such violence. This ruling establishes that the identity of an abuser in an intimate relationship is directly relevant to a victim's comprehensive medical care, including mental health and safety planning. This precedent provides prosecutors with a vital evidentiary tool, allowing crucial identifying statements to be admitted through medical personnel, especially in cases where victims are unable or unwilling to testify against their abusers.
