State v. Carter, 216 N.C. App. 453 (Nov. 1, 2011)

(1) In a child sexual assault case, the trial court did not err by declining to admit defense-proffered evidence offered under the hearsay exception for excited utterances. The evidence was the victim’s statement to a social worker made during “play therapy” sessions. Because the record contained no description of the victim’s behavior or mental state, the court could not discern whether she was excited, startled, or under the stress of excitement when the statement was made.