State v. Jackson

¶ 1. Defendant Aaron Jackson appeals from his convictions, after a jury trial, for kidnapping, 18 V.S.A. § 2405(a)(1)(C), unlawful restraint, id. § 2407(a)(1), and two counts of simple assault by physical menace, id. § 1023(a)(3). Defendant received concurrent terms of seven to thirteen years on the kidnapping and restraint convictions and zero to one year on each of the menace convictions. In this appeal, he contends that the trial court erred by: (1) admitting certain identification evidence without conducting a Wade hearing; (2) admitting a hearsay statement as an excited utterance under…