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State v. Jones
311 Md. 23 (1987)
Facts: Victim claimed that D (state trooper) sexually
assaulted her and then her and her friend chased the trooper who left at a high
rate of speed. Prosecution’s witness, another officer, testified that he heard
on police radio statements made by some unknown truckers about how the a police
car was going at a high rate of speed without its headlight on and how a small
car was chasing it. Trial Court admitted these statements under present sense
impressions exception. D claims that since statements not corroborated,
shouldn’t have been admitted.
Issue: Is corroboration required under present sense
impression exception?
Holding: No
Rationale: A statement is admissible under the present
sense impressions exception if the statement is describing an event, occurs
shortly after the event takes place, and is based on declarant’s personal
knowledge of the event. Therefore, the statements of the unknown declarants in
this case were admissible without corroboration.
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