In the Interest of J.C.

While visiting a friend’s house, 12-year-old J.C. (defendant) sexually abused a four-year-old girl, A.W., by partially taking her clothes off and touching her. A relative of A.W. witnessed this and pulled J.C. off A.W. A.W.’s mother contacted the police, who later instructed A.W.’s parents to have her interviewed at the Child Protection Response Center (the center). During the interview, A.W. disclosed the abuse. The interview was recorded and observed by law enforcement. Law enforcement told A.W.’s parents to have her seen by Dr. Barbara Harre, the center’s medical director. Over one month after the alleged abuse occurred, Harre questioned A.W. without police present, conducted a physical exam, and prepared a report regarding A.W.’s disclosure addressed to the assistant county attorney who prosecuted J.C. The state of Iowa (plaintiff) filed a petition alleging J.C. was delinquent, and a hearing was held. A.W. did not testify, but there was testimony from the relative who pulled J.C. off A.W. and from other witnesses. The juvenile court did not allow the recording of the forensic interview or the related report to be admitted. However, over J.C.’s objections, the court admitted Harre’s written report and permitted Harre and the forensic interviewer to testify regarding what A.W. disclosed. J.C. was adjudicated delinquent upon the court’s finding that J.C. assaulted A.W. with an intent to commit sexual abuse. An appellate court affirmed, noting that any error related to admitting the forensic interviewer’s testimony was harmless error. J.C. requested that the Iowa Supreme Court review the case to determine whether the Sixth Amendment’s Confrontation Clause had been violated.