State v. Garcia-Trujillo

A witness may not testify to the content of another’s extrajudicial statement if the testimony is based on a translation rather than the witness’s understanding of the declarant’s words unless the testimony is not offered for the truth of the matter asserted or the interpreter is an agent of the declarant. Manuel Garcia-Trujillo (Garcia) contends the trial court improperly admitted rebuttal testimony by the investigating detective about a statement Garcia made through an interpreter. The State cross-appeals, arguing that the trial court improperly excluded other testimony by the same…