How has the totality of the circumstances test been applied to statements made by a non-testifying victim?

MultiRegion, United States of America

The following excerpt is from Luttrell v. Gipson, No. 2:13-cv-0476 TLN GGH P (E.D. Cal. 2014):

2. Idaho v. Wright applied a totality of the circumstances test to out-of-court statements made by a non-testifying victim to determine their indicia of reliability and trustworthiness. 497 U.S. at 814-816, 818, 820-21.

3. Section 1360, subdivision (a) reads:

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