Warren v. State

This case requires us to clarify further the application of two exceptions to the rule against hearsay. Specifically, we address whether recordings of two 911 calls are admissible under the hearsay exception for present sense impressions. We conclude that some of the statements during the second recorded 911 call do not fall within the present sense impression exception because they referred to incidents that occurred more than one hour earlier. Nevertheless, we conclude that admission of these statements was not error because they fall within the hearsay exception for excited utterances.

We…