The People of the State of New York v. Michael Spicola

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the nurse‑practitioner’s testimony was admissible under the diagnosis‑and‑treatment exception and that the expert’s testimony on child sexual abuse accommodation syndrome (CSAAS) was admissible to explain delayed reporting, and it rejected the defendant’s claims of improper bolstering; Chief Judge Lippman dissented, arguing both evidentiary rulings were improper and warranted reversal.