The dual nature of the exams has also supported the court of appeals' conclusion that a victim's statement to a SANE can constitute a statement made for the purposes of medical diagnosis or treatment under C.R.E. 803(4). See People v. Tyme , 2013 COA 59, ¶¶ 9, 16–17, 315 P.3d 1270, 1272–73 (noting statements made to a SANE for treatment purposes may be admissible but those made for purely investigative purposes may not be). We, too, conclude that SANE exams at once serve both investigative and medical purposes. We are aware that the division in Montanez , ¶ 22, 300 P.3d at 944, pointed to section 18–3–407.5, C.R.S. (2016), as obligating law enforcement to pay for a SANE exam at a victim's request, yet that statute merely identifies the party required to pay in the first instance. It does not speak to whether law enforcement may then seek to recover its costs.

The dual nature of the exams has also supported the court of appeals' conclusion that a victim's statement to a SANE can constitute a statement made for the purposes of medical diagnosis or treatment under C.R.E. 803(4). See People v. Tyme, 2013 COA 59, ¶¶ 9, 16-17, 315 P.3d 1270, 1272-73 (noting statements made to a SANE for treatment purposes may be admissible but those made for purely investigative purposes may not be). We, too, conclude that SANE exams at once serve both investigative and medical purposes. We are aware that the division in Montanez, ¶ 22, 300 P.3d at 944, pointed to section 18-3-407.5, C.R.S. (2016), as obligating law enforcement to pay for a SANE exam at a victim's request, yet that statute merely identifies the party required to pay in the first instance. It does not speak to whether law enforcement may then seek to recover its costs.

Galloway in turn relied upon Stiles, 692 P.2d at 1127–28 (citing Iron Shell, 633 F.2d at 83), overruled in part by King, 785 P.2d at 599. The court of appeals has applied the two-part test in other cases as well, including People v. Jaramillo, 183 P.3d 665, 669 (Colo.App.2008), cert. denied,2008 WL 2174055 (Colo.2008); and People v. Tyme, 2013 COA 59, ¶¶ 9–10, 315 P.3d 1270, 1272 (Colo.App.2013).¶ 38 As applied in this case, Hurd's statements were made for the purpose of medical diagnosis, as noted above.

¶ 61 We review a trial court's evidentiary rulings for an abuse of discretion. People v. Tyme , 2013 COA 59, ¶ 8, 315 P.3d 1270. A trial court abuses its discretion when its ruling is manifestly arbitrary, unreasonable, or unfair, or if it misapplies the law.

rd. See id. at ¶ 24 (if a statement is offered for the purpose of determining the nature, source, or cause of a patient's medical condition, it falls within the language of CRE 803(4), regardless of whether it is accompanied by treatment); id. at ¶ 30 (drug use is part of a patient's medical history and is an important indicator of a patient's physical condition); id. at ¶ 31 (statements regarding past drug use would be reasonably pertinent to determining the cause of—that is, to diagnose—the patient's condition); King , 785 P.2d at 603 (once the proponent of the hearsay statements establishes that they were made to a physician for purposes of either diagnosis or treatment, and that such statements were reasonably pertinent to diagnosis or treatment and were relied on by the physician in arriving at an expert opinion, the statements themselves qualify for admission under CRE 803(4) without regard to any independent demonstration of trustworthiness); People v. Tyme , 2013 COA 59, ¶ 20, 315 P.3d 1270 (upholding admission of testimony by sexual assault nurse examiner (SANE) that she relied on the medical history to guide her examination of the victim and used it to diagnose and treat, and that SANEs normally rely on similar histories to guide diagnosis and treatment, thereby demonstrating the reasonableness of reliance on statements by victim); see also Weaver v. State , 290 Ark. 556, 720 S.W.2d 905, 907 (1986) (blood alcohol test ordered by emergency room physician for use in treatment of a patient was admissible under Ark. R. Evid. 803(4) ); Tracy A. Bateman, Annotation, Admissibility of Statements Made for Purposes of Medical Diagnosis or Treatment as Hearsay Exception Under Rule 803(4) of the Uniform Rules of Evidence , 38 A.L.R.5th 433 (2011) (collecting cases). ¶ 18 Mother's reliance on Leiting v. Mutha , 58 P.3d 1049 (Colo. App. 2002), for a different result, is misplaced.

¶ 27 Generally, we review a trial court's evidentiary rulings for an abuse of discretion. People v. Tyme, 2013 COA 59, ¶ 8, 315 P.3d 1270. But when a defendant asserts that the trial court's evidentiary rulings violated his confrontation rights, we review de novo.