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State v. Sanchez, 2016 UT App 189 (Sept. 1, 2016)

Sep 1, 2016

In an appeal from convictions for murder and obstruction of justice, defendant argued the lower court erred in excluding portions of a police interview in which defendant stated he fought with victim based on victim’s statements about an affair with his brother. Affirming, the Court of Appeals held, as a matter of first impression, that Rule of Evidence 106 permits admission of hearsay statements that do not otherwise qualify for exception to the hearsay rule, so long as the hearsay statement satisfies Rule 106’s fairness standard.