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State v. Lawrence

Louisiana Supreme Court
752 So.2d. 934 (1999)


Facts

Michael A. Lawrence (defendant) was convicted of charges involving his sexual abuse of his 12-year-old niece, D. M. After D. M. reported the abuse to her parents, her parents notified the police and scheduled an appointment with her pediatrician, Dr. Janet D. Barnes. The police also scheduled D. M. to be seen by Dr. Katheryne A. Coffman, the director of the sexual-abuse program at a local children’s hospital. During D. M.’s appointment with Dr. Barnes, Dr. Barnes examined her for the purpose of treating her, taking samples as well. Dr. Barnes tested D. M. for sexually transmitted diseases, and she notified D. M.’s mother of the results a few days later. Dr. Barnes also referred D. M. to a therapist for counseling. In contrast, Dr. Coffman’s examination was for the primary purpose of gathering forensic evidence and no treatment was recommended and follow-up was not expected. During Lawrence’s trial, both Dr. Barnes and Dr. Coffman testified about D. M.’s statements to them during their examinations of her. Lawrence objected to both, arguing they were hearsay, but the trial court overruled his objections and admitted the testimony of both physicians. Following his conviction, Lawrence appealed, claiming the trial court erred in admitting the physicians’ testimony regarding D. M.’s statements.

Rule of Law

Issue

Holding and Reasoning (Murray, J.)

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