Brown v. United States

“[T]he excited utterance exception is just that — an exception to the hearsay rule, and it should not be construed so broadly that it renders the hearsay rule ineffectual.” State v. Branch, 182 N.J. 338, 865 A.2d 673, 690 (2005) (emphasis in original). “Over the years, some of our cases have imported a measure of flexibility into the admissibility calculus of spontaneous exclamations and excited utterances, but the fundamentals of the doctrine have remained intact.” Odemns v. United States, 901 A.2d 770, 778 (D.C.2006). On this record, I conclude that Mr. Brown’s utterances were neither…