California, United States of America
The following excerpt is from People v. Jeffery, 37 Cal.App.4th 209, 43 Cal.Rptr.2d 526 (Cal. App. 1995):
On the other hand, when the out-of-court statements are not given under suspect circumstances, those statements do not qualify as "testimony" and hence need not be corroborated under section 1111. Thus, in People v. Sully (1991) 53 Cal.3d 1195, 1230, 283 Cal.Rptr. 144, 812 P.2d 163, the high court, citing Pic'l, held that out-of-court statements given under circumstances which fall within the spontaneous statement exception to the hearsay rule are not given in suspect circumstances and hence do not constitute testimony for purposes of the statute.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.