";s:4:"text";s:29459:"491 (2007). (C) Factual findings offered by the government in criminal cases. Excited Utterance. Under Rule 801(d)(1)(B), prior consistent statements are also not hearsay if the declarant testifies at the trial, is subject to cross-examination, and the statement is introduced to rebut a charge that the declarant fabricated their testimony or has an improper influence or motive. Even assuming that the evidence had a hearsay component, when a statement has both an impermissible hearsay aspect and a permissible non-hearsay aspect, a court should generally admit such evidence with a limiting instruction, unless the probative purpose of the statement is substantially outweighed by the danger of its improper use. Spragg,293 N.J. Super. Overview of Hearsay Exceptions. Excited Utterance. State v. Long, 173 N.J. 138, 152 (2002). 545 (2011) (statements were not hearsay because they were offered to show officers subsequent action); State v. Banks, 210 N.C. App. The Sixth Amendment to the Constitution provides that "in all criminal prosecutions, the accused shall enjoy the right to be confronted with the witnesses against him." In the case of hypothetical 1, only the fact at most that upon information received at the scene of the 7-Eleven robbery and murder, the detective proceeded to an apartment building at, etc., should be introduced and not the content of Marys statement that John was the perpetrator. 177 (2000) (The trial court admitted the written statement not as substantive evidence, but for the limited purpose of corroborative evidence only, which does not constitute hearsay.); State v. Coffey, 326 N.C. 268 (1990) (statements about what child reported were admissible to corroborate mothers testimony); State v. Riddle, 316 N.C. 152 (1986) (Collins' testimony was not offered to prove the truth of the matter asserted [] but was offered merely to prove that Pamela had made a statement to this effect to Collins. Officer Paiva's statements occurred in the context of, and were admitted to show, a give-and-take conversation with Jones. at 57. Definitions That Apply to This Article. State v. Cunningham, 337 Or 528, 99 P3d 271 (2004), Where defendant assaulted and threatened victim then held victim captive after assault, and victim made statements to third party upon victim's escape 24 hours after assault, victim's statements were "excited utterance" as used in this section because victim was under continuous emotional shock or unabated fright when victim made statements. If any one of the above links constituted inadmissible hearsay, State v. Barber, 209 Or App 604, 149 P3d 260 (2006), Sup Ct review denied, Residual exception as basis for admission of hearsay ordinarily may not be asserted for first time on appeal. See State v. Black, 223 N.C. App. WebOpinion and reputation testimony allowed under Rule 404 (the character evidence rules) is also exempted from the hearsay rules even though they inevitably arise from second Once a statement qualifies under Rule 801(d)(1)(A), on the other hand, it can be used for any purpose for which it is relevant. 517 (2009) (evidence offered for corroboration and not as substantive evidence will not be excluded as hearsay); State v. Guice, 141 N.C. App. However, if the context or substance of the question or directive indicates that it should be understood as an assertion and it is being offered to prove the truth of the matter asserted, then the question or directive should be viewed as a statement subject to the hearsay rules. entrepreneurship, were lowering the cost of legal services and 8C-801, 802; State v. Burke, 343 N.C. 129 (1996). Federal practice will be con-trasted with the Illinois position. Such knowledge, notice, or awareness, etc., is relevant when the probable state of mind of the listener is itself an issue. Mattox v. U.S., 156 U.S. 237, 242-43 (1895). Cookie Settings. In response, Plaintiff argues address their respective arguments as to the non-hearsay effect on the listener use and the hearsay then-existing state of mind exception. The rationale for allowing these kinds of statements into evidence is that [s]ince the law accords the making of such statements a certain legal effect, the sincerity and reliability of the declarant is of no consequence; the simple fact that those statements were made is relevant. 31A C.J.S. Accordingly, the statements did not constitute impermissible opinion evidence. The opinion of plaintiffs expert was consistent with that of the interpreting radiologist, who was not testifyingat trial. 2015) (alteration in original) (quoting N.J.R.E. 403, as providing context to the defendants response. Evidence 503. An excited utterance may be made immediately after the startling event, or quite some time afterward. WebRule 5-804 - Hearsay Exceptions; Declarant Unavailable. (16) [Back to Explanatory Text] [Back to Questions] 103. Plaintiffs counsel did not attempt to use Dr. Arginteanus recommendation to show that Dr. Dryer disregarded relevant facts or to present Dr. Arginteanus treatment recommendation as a tie breaker between competing expert opinions. 30 (2011). 1992) (holding that statements made to plaintiff regarding the limitations of his activity were not hearsay when offered to prove offered to prove that plaintiff limited his activity based upon advice given to him.). And yes, not hearsay is not hearsay because it doesn't even meet the FRE rule definition for hearsay. Definitions for ORS 40.450 to 40.475) to 40.475 (Rule 806. L. 9312, Mar. Here is a short list and description of some the most useful hearsay exceptions: Party admissions; Admissions are described above. The statutory exceptions that allow hearsay to be admitted into evidence are addressed in the following entries: In addition to the statutory hearsay exceptions listed above, there are many situations in which the statement of a declarant is admissible simply because it does not fall within the scope of Rule 801 and therefore it is not subject to exclusion. The statement's existence can be proven with extrinsic evidence if the declarant denies having made the statement. State v. McKinzie, 186 Or App 384, 63 P3d 1214 (2003), Sup Ct review denied, Inclusion of statement in discovery provided to defendant does not satisfy requirement that prosecution provide timely notice of intent to present statement at trial. 803(4). For information about hearsay evidence that is admissible as an admission of a party-opponent, see the related Evidence entry regarding, For information about hearsay evidence that is admissible as an exception regardless of the availability of the declarant, see the related Evidence entry regarding, For information about hearsay evidence that is admissible as an exception based on the unavailability of the declarant, see the related Evidence entry regarding. 36 (1989) (there was no hearsay-within-hearsay problem presented here because the statements of the third party declarants were not offered for their truth, but to explain the officer's conduct). 472 (2007) (unpublished) (yearbook photos used by victim to identify suspects were not hearsay). v. Cornett, 121 Or App 264, 855 P2d 171 (1993), Admissibility of videotape depends on admissibility of statements contained in it. 803(1). address their respective arguments as to the non-hearsay effect on the listener use and the hearsay then-existing state of mind exception. 80, 83-84, 1 P.3d 1058 (2000) (trial court erred in excluding as hearsay witness's out-of-court statement offered to prove the effect on the Rules 803 and 804 deal with exceptions to the hearsay rulestatements which are hearsay, but are nevertheless admissible. (b) Declarant. Rule 613 allows all of a witness's prior inconsistent statements to be admitted for the sole purpose of impeachment, or discrediting their testimony. WebNon Hearsay due to effect on listener vs state of mind exception Hi all, I just had a problem with the answer being no because its not hearsay since it is being offered to show the Health Plan, 280 N.J. Super. There are a number of exceptions to the hearsay rule (including present-sense impression, excited utterances, declarations of Examples of such statements probably include statements to police and official reports during a criminal investigation. 2013) (After carefully reviewing the record, we find no abuse of discretion in the trial court's decision to admit the full transcript of Jones's interrogation. See also annotations under ORS 41.670, 41.680, 41.690, 41.840, 41.870 and 41.900 in permanent edition. State v. Chase, 240 Or App 541, 248 P3d 432 (2011), Statement made by special victim of sexual conduct, Intention of legislature under this rule is that defendant not be convicted on hearsay alone. at 51. Allowing testimony regarding the content of an informant's out-of-court statement often involves statements having hearsay components. While the Michigan Supreme Court has opined that it finds it unnecessary to adopt a bright-line rule for the automatic exclusion of out-of-court statements made in the context of an interrogation that comment on another persons credibility, ultimately the Michigan Supreme Court in fact joins the Florida Supreme Court and the Massachusetts Supreme Court in precluding admissibility of the content of all police officers statements made during an interrogation that proceeds as detailed above. Written, oral, or nonverbal communication is a statement subject to the hearsay rules only if the communication is intended as an assertion. See G.S. This page was processed by aws-apollo-l1 in. State v. Jones, 27 Or App 767, 557 P2d 264 (1976), Sup Ct review denied, This Rule permits officer who testifies in criminal trial to read relevant parts of his report into record when he has insufficient present recollection to testify fully and accurately. 20. The statement is only admissible to prove the declarant's condition: if others are included in the statement, the statement will not be admissible to prove anything related to the others. Annotations are listed under the heading "Under former similar statute" if they predate the adoption of the Evidence Code, which went into effect January 1, 1982. See, e.g., Rules 11-803 (hearsay exceptions; availability of declarant immaterial); 11-804 (hearsay exceptions; declarant unavailable); 11-807 (residual exceptions to hearsay). 8C-801(a). Jurisdiction: Territorial, Personal, & Subject Matter, Jurisdiction of Officers and Judicial Officials, Experts/Resources for Indigent Defendants, Suggested Questions for Mental Health Expert, Relevance & Admissibility [Rules 401, 402], Prejudice, Confusion, Waste of Time [Rule 403], Other Crimes, Wrongs, or Acts [Rule 404(b)], Impeachment: Character & Conduct [Rule 608], Impeachment: Religious Beliefs [Rule 610], Hearsay: Definition & Admissibility [Rules 801, 802], Admission of Party Opponent [Rule 801(d)], Medical Diagnosis/Treatment [Rule 803(4)], Reputation as to Character [Rule 803(21)], Statement Against Interest [Rule 804(b)(3)], Personal or Family History [Rule 804(b)(4)], Residual Exceptions [Rules 803(24), 804(b)(5)], Subscribing Witness Unnecessary [Rule 903], The Explains Conduct Non-Hearsay Purpose. WebARTICLE VIII. See, e.g., State v. Weaver, 160 N.C. App. Docket No. There can be any number of intermediaries in the chain, so long as each statement between declarant and reporter corresponds to a hearsay exception. State v. Harris, 78 Or App 490, 712 P2d 242 (1986), Statements to 911 dispatcher and statements made to responding police officer qualified as excited utterances. See State v. Patterson, 332 N.C. 409 (1992) (composite sketch, based on descriptions given by eyewitnesses, was not hearsay however, state failed to lay a proper foundation to show that sketch accurately portrayed the men the witnesses had seen); State v. Jackson, 309 N.C. 26 (1983) (noting that, if properly authenticated, sketches, and composite pictures are admissible to illustrate a witness's testimony); see also State v. Commodore, 186 N.C. App. In this case, the question posed to Dr. Dryer did not seek to establish that his opinion was consistent with Dr. Argintineus opinion; rather it simply asked whether Dr. Dryer himself felt that a fusion was an appropriate treatment for a syrinx. (last accessed Jun. WebThe following are not within this exception to the hearsay rule: (A) Investigative reports by police and other law enforcement personnel; (B) Investigative reports prepared by or for a government, a public office, or an agency when offered by it in a case in which it is a party; and. At least one case has held that a composite image prepared by a police sketch artist is not hearsay, even though that sketch is based on (and presumably reflects) the out-of-court descriptions of the perpetrator provided by other witnesses. HEARSAY Rule 801. Such statements may be relevant in other contexts as a circumstance under which the later acted or as bearing upon the likelihood of later disputed conduct, e.g., providing a motive or reason for later disputed conduct. Unless the defendant can (or could) cross-examine the declarant, the statement is inadmissible, even if it meets a hearsay exception under the Federal Rules. See, e.g., State v. Jones, 398 S.W.3d 518, 526 (Mo.App. 802. Hearsay requires three elements: (1) a statement; (2) To stay away, constituted hearsay under Rule 801(a).). 1 (2002) ("A careful reading of the testimony reveals that the remaining portions of the challenged testimony were not offered for the truth of the matter asserted, rather they were offered for the non-hearsay purposes of showing state of mind and effect on the listener. Then-Existing Mental, Emotional, or Physical Condition. 1 / 50. Hearsay is not admissible except as provided by statute or by these rules. We find no error in the trial courts evidentiary ruling, and the cursory and indirect reference to the note by Dr. Dryer is not a basis to overturn the verdict. Civil LawCriminal LawTruck AccidentsWorkers Compensation, 1101 Marlton Pike West, Cherry Hill, NJ 08002, 2021 Criminal Civil Lawyer All Rights Reserved Practicing in all NJ Counties Sitemap. Suggested Citation:
Rule 803 (5) provides an exception to the rule against hearsay for a record that " (A) is on a matter the witness once knew about but cannot recall well enough to testify fully and accurately; (B) was made or adopted by the witness when the matter was fresh in the witness's memory, and (C) accurately reflects the witness's knowledge." Rule 801 establishes which statements are considered hearsay and which statements are not. A hearsay objection is made when a witness relates the actual content of an out-of-court communication. State v. Renly, 111 Or App 453, 827 P2d 1345 (1992), Victim recantation of prior statements does not render otherwise competent victim unable to communicate or testify in court. Conceptually, this is really just a sub-set of statements that are not offered for the truth of the matter asserted, but the case law has particularly recognized that statements which are offered for the nonhearsay purpose of explaining why a person took a particular course of action (explains conduct) or reacted in a certain way to that statement (effect on the listener) are not excluded as hearsay under Rule 801. State v. Cazares-Mendez/Reyes-Sanchez, 350 Or 491, 256 P3d 104 (2011), State v. O'Brien, 6 Or App 34, 485 P2d 434, 486 P2d 592 (1971), aff'd262 Or 30, 496 P2d 191 (1972), 22 WLR 421 (1986); 26 WLR 402, 406, 423 (1990); 37 WLR 299 (2001); 82 OLR 1125 (2003), General rule is that polygraph evidence is inadmissible in proceeding governed by Oregon Evidence Code. State v. Clegg, 332 Or 432, 31 P3d 408 (2001), Statements made for purposes of medical diagnosis or treatment, When it is shown that physician reasonably relied on child-victim's identification of her abuser as member of her family in diagnosing and treating victim, physician's testimony about victim's identification of her abuser is admissible. - (a) OK to show D was on notice of broken jar - (b) NOT admissible to prove there actually was a broken jar of salsa State v. Vosika, 83 Or App 298, 731 P2d 449 (1987), Testimony of two physicians, including victim's identification of defendant as person who had sexually abused her, was admissible as statement for medical diagnosis or treatment because physician would reasonably rely on statements and record supports finding that victim understood she was being interviewed and examined for diagnosis and treatment. Evidence is hearsay if it is a statement (that is, an assertion, either oral or written), made by the declarant (i.e., the person who made the statement) at any time or place other than while testifying in court at the current trial or hearing, and the statement is being offered to prove the truth of the matter asserted. Defendant contends that plaintiffs cross-examination of Dr. Dryer ran afoul of the standards set forth in James v. Ruiz, 440 N.J. Super. This page was last edited on 5 November 2019, at 17:55. Therefore, statements that do not assert any facts, such as questions (what time is it?) or instructions (get out of here), may be admissible as nonhearsay. A child's statement to a parent, or an elderly person's statement to the younger relative taking care of them, could both be 803(4) statements. (Any of several deviations from the hearsay rule, allowing the admission of otherwise inadmissible statements because Since each statement in the chain falls under a hearsay exception, the statement is admissible. 801(a)-(c): Effect on Listener-Investigatory Background; Interrogation Accusations and Opinions (August 3, 2018). We held that the plaintiff could not ask a medical expert witnesses whether their reading of the CT scan was consistent or inconsistent with that of a non-testifying radiologist, thereby utilizing the radiologists report as a tie breaker on the contested issue of whether plaintiff had disc bulges. Even if it were hearsay, it would, however, be within the state of mind exception to the hearsay rule, FRE 803(3). 699 (2016) (detectives testimony about what was written in an instruction manual for the air pistol he was testing was not hearsay, because it was offered for the nonhearsay purpose of explaining why he set up the test the way he did); State v. Stanley, 213 N.C. App. Article VIII of the Federal Rules of Evidence deals with hearsaythe rule that a statement made out of court may not be admitted for its truth. Hearsay exceptions; declarant unavailable Section 805. WebIf a statement is offered to show its effect on the listener, it will generally not be hearsay. A statement of a then-existing condition must be "self-directed": either describing what the declarant is feeling or what the declarant plans to do. Note: Rule 801(d) is covered separately in the next entry on Admission of a Party Opponent.. Original Source: The court also determined that each of the allegations in the statement was supported by testimony from prior witnesses and, thus, was supported by evidence already in the record. 21 II. 30 (2011) (officers testimony about where another witness told him the gun could be found was not hearsay, because it was offered to explain officers subsequent actions of notifying his supervisor and locating the gun); State v. Elkins, 210 N.C. App. WebTestimony of mother recounting statement made by three-year-old victim to mother about sexual attacks by defendant were admissible as exception to hearsay rule allowing (c) Hearsay. Here, the MRI scan finding of a syrinx was undisputed and the statements did not pertain to the central disputed issue of causation. State v. Kitzman, 323 Or 589, 920 P2d 134 (1996), Where victim testifies and is available for cross-examination, "child" means unmarried person under 18 years of age. 33, 57 (App. 78, disc. See, e.g., State v. McLean, 251 N.C. App. Id. State v. Smith, 66 Or App 703, 675 P2d 510 (1984), Admissibility of Intoxilyzer certifications as public records exception to hearsay rule does not violate constitutional right to confrontation of witnesses. State v. Moen, 309 Or 45, 786 P2d 111 (1990), Statements made by child victim to physician and to physician's assistant about sexual abuse by defendant were admissible as statements made for purposes of medical diagnosis or treatment, even though reason victim was taken to physician was for possible diagnosis of sexual abuse. These statements come in, however, under the "state of mind" exception if made at the time in which the declarants state of mind is relevant. by: Ryan Scott December 16, 2016 one comment. See Carmona v. Resorts Intl Hotel, Inc., 189 N.J. 354, 376 (2007) (Where statements are offered, not for the truthfulness of their contents, but only to show that they were in fact made and that the listener took certain action as a result thereof, the statements are not deemed inadmissible hearsay. (quoting Russell v. Rutgers Cmty. WebThis is not hearsay. A statement describing The 2021 Florida Statutes. 850 (2017) (witnesss statement that jailer told her the defendant was in an adjacent cell was not hearsay, because it was offered for the nonhearsay purpose of explaining why the witness was afraid to testify); State v. Castaneda, 215 N.C. App. It is just a semantic distinction. The testimony was therefore not objectionable on hearsay grounds.). Records of regularly conducted activity (ORS 41.690), This section vests considerable discretion in trial judge concerning admissibility. WebThere are a number of exceptions to the hearsay rule (including present-sense impression, excited utterances, declarations of present state of mind, dying and the business records exceptions), as well as things defined not to be hearsay (admission of a party-opponent, and prior statements of a witness). However, hearsay evidence or testimony can be valuable evidence for judges or juries when deciding a case. 1 Jones v. U.S., 17 A.3d 628 (D.C. 2011) (On proper objection, the party seeking admission of the out-of-court statement has the burden to identify the appropriate exception and to explain how it is applicable). 803(4) statements do not have to be made to medical professionals; the declarant may make the statement to any caretaker figure. 315 (2018) (statements by a confidential informant to law enforcement officers which explain subsequent steps taken by officers in the investigative process are admissible as nonhearsay); State v. Rogers, 251 N.C. App. This field is for validation purposes and should be left unchanged. Is the Translation or Interpretation of Anothers Statements Hearsay? Jones's statements during the interrogation were made in response to specific questions by Officer Paiva, and the text of those questions was therefore helpful to understand the full context of Jones's answers. Distinguishing Hearsay from Lack of Personal Knowledge. 249 (7th ed., 2016) (collecting cases and examples of other verbal acts). this Court does not believe fall under the cited hearsay exceptions, the People would seek to admit them for their effect on the listener, and not to the truth of the matter asserted. Since the listener is on the stand and can attest to the statement he or she heard, the listener can be cross examined on his or her memory and perception of what he or she heard. Rule 5-806 - Attacking and Supporting Credibility of Declarant. 82 (2020) (where the only statements directly linking defendant to robbery were admitted for a limited nonhearsay purpose, there was insufficient evidence to support conviction). WebThe effect is to exclude from hearsay the entire category of verbal acts and verbal parts of an act, in which the statement itself affects the legal rights of the parties or is a circumstance bearing on conduct affecting their rights. The statement is circumstantial evidence of the declarant's state of mind of hostility towards D just by the fact that it was made. 802. we provide special support WebTutorial on the crimes of stalking and harassment for New Mexico judges. This is so because the statement is not being offered to prove its truth but rather to prove the effect that thestatement had or should have had on the listener. 40.460 2013) (In the present case, the court admitted Parrott's testimony setting forth what DE told her, concluding that it was not offered for its truth, but to provide context to the defendant's response to this statement. 803(3). 869 (2017), revd on other grounds, 371 N.C. 397 (2018) (officers statements about information collected from nontestifying witnesses were admissible for nonhearsay purpose of explaining officers subsequent actions taken in the investigation); State v. Chapman, 244 N.C. App. 4. If any one of the above links constituted inadmissible hearsay, the statement would be inadmissible. The plaintiffs expert in James opined that plaintiffs CT scan showed a disc bulge, whereas the defendants expert opined that there was no disc bulge shown on the CT scan. 123, 136-37 (App. This confrontation clause has been interpreted as a further restriction on the admissibility of statements by out-of-court declarants in criminal cases. The statement can also be admitted as substantive evidence of its truth. declarant is admissible simply because it does not fall within the scope of Rule 801and therefore it is not subject to exclusion. Hearsay Exceptions: Availability of Declarant Immaterial . 249 (7th ed., 2016). See, e.g., State v. McQueen, 324 N.C. 118 (1989) (question that a companion asked the defendant you dont remember killing a state trooper? was inadmissible hearsay since it was offered to prove the truth of the matter asserted: namely, that the defendant had no recollection of the killing); State v. Marlow, 334 N.C. 273 (1993) (Clearly, Horton's oral assertion that he told Howell not to come back around. 144 (2011) (statements in detectives interview with defendant about what other witnesses allegedly saw defendant do were not hearsay, because they were offered for the nonhearsay purpose of giving context to the defendants answers and explaining the detectives interview technique); State v. Brown, 350 N.C. 193 (1999) (statements made to victim about getting a divorce were not offered for truth of the matter); State v. Davis, 349 N.C. 1 (1998) (statements about defendant being fired were offered for nonhearsay purpose of showing motive); State v. Dickens, 346 N.C. 26 (1997) (recording of statements made in 911 call was admissible for nonhearsay purpose of showing that call took place and that the accomplice was the caller); State v. Holder, 331 N.C. 462 (1992) (statement properly admitted to show state of mind); State v. Tucker, 331 N.C. 12 (1992) (trial court erred in precluding admission of the statements because they were either nonhearsay or admissible under a hearsay exception); State v. Woodruff, 99 N.C. App. See, e.g., State v. Robinson, 355 N.C. 320 (2002) (testimony from one witness about whether another witness had pointed anyone out in a mug shot book was inadmissible hearsay); State v. Marlow, 334 N.C. 273 (1993) (Howell's actions of attempting to give Horton the tape player and later attempting to give him a twenty-dollar bill were nonverbal assertions also constituting hearsay); State v. Satterfield, 316 N.C. 55 (1986) (declarants gesture, in response to officers question, of pointing to the drawer where knife could be found was nonverbal conduct intended as an assertion, and therefore inadmissible as hearsay). WebThe following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. Sleigh v. Jenny Craig Weight Loss Centres, Inc., 161 Or App 262, 984 P2d 891 (1999), modified 163 Or App 20, 988 P2d 916 (1999), Testimony of mother recounting statement made by three-year-old victim to mother about sexual attacks by defendant were admissible as exception to hearsay rule allowing complaint of sexual misconduct by prosecuting witnesses; it is unnecessary for child victim to testify as precondition for admission of child's complaint of sexual misconduct. For more information about impeachment, including the circumstances when extrinsic evidence such as a prior statement may be used to impeach, see the related Evidence entry on Impeachment: Generally [Rule 607]. (b) The Exceptions. Rule 801(d)(1)(c) It's a statement that is not hearsay. It is well established that hearsay is not admissible at trial unless an exception applies. State v. Verley, 106 Or App 751, 809 P2d 723 (1991), Sup Ct review denied; State v. Barkley, 108 Or App 756, 817 P2d 1328 (1991), aff'd 315 Or 420, 846 P2d 390 (1993); State ex rel Juv. Even if it were hearsay, it would, however, be within the state of mind exception to the hearsay rule, FRE 803(3). The following are not excluded by the rule against hearsay if the declarant is unavailable as a witness: (1) Former Testimony. Web90.803 - Hearsay exceptions; availability of declarant immaterial. Abstract. 803(2). Id. 403 and should no longer be countenanced.Interrogation Accusations and OpinionsStatements made during law enforcement interrogation of a person, usually the criminal defendant, as part of a conversation, i.e., responded to by the person being interrogated, are not hearsay when admitted for the fact said, subject to Fed.R.Evid. ";s:7:"keyword";s:36:"effect on listener hearsay exception";s:5:"links";s:169:"Apostolic United Brethren,
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