What is the test for admitting multiple levels of hearsay in a criminal case?

California, United States of America


The following excerpt is from Correa v. Superior Court, 101 Cal.Rptr.2d 242, 84 Cal.App.4th 631 (Cal. App. 2000):

The framers of, and the voters for, Proposition 115 sanctioned only the admission of single-level hearsay from a properly trained investigating officer. Because of its limitations, the measure satisfies federal requirements of reliability. (Whitman v. Superior Court, supra, 54 Cal.3d at p. 1074.) However, it would not pass constitutional muster if expanded to include multiple hearsay where the defendant is deprived of the opportunity to meaningfully cross-examine the testifying officer regarding the accuracy of the translated out-of-court statements.

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