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Nebraska Revised Statutes

Neb. Rev. Stat. § 27-805 (2026)

Rule 805. Hearsay within hearsay

✓ current as of July 2026
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Hearsay included within hearsay is not excluded under the hearsay rule if each part of the combined statements conforms with an exception to the hearsay rule provided in these rules.

Notes of Decisions
Cited in 11 cases (6 in the last 5 years), 1987–2026 · leading case: State v. Swartz, 318 Neb. 553 (Neb. 2025).
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State v. Swartz, 318 Neb. 553 (Neb. 2025). · cites it 2× “” Neb. Rev. Stat. § 27-805 (Reissue 2016). When an out-of-court statement relates the content of another out-of-court statement, there must be an independent hearsay exception for each statement.”
Behm v. Nw. Bell Tel. Co., 491 N.W.2d 334 (Neb. 1992). · cites it 4× “See Neb.Rev.Stat. § 27-805 (Reissue 1989) ("[h]earsay included within hearsay is not excluded under the hearsay rule if each part of the combined statements conforms with an exception to the hearsay rule provided in these rules").”
State v. Ramos, 319 Neb. 511 (Neb. 2025). · cites it 2× “2024) (defining hearsay); Neb. Rev. Stat. § 27-805 (Reissue 2016) (defining double hearsay).”
State v. Corral, 318 Neb. 940 (Neb. 2025). · cites it 2× “131 See Neb. Rev. Stat. § 27-805 (Reissue 2016). 132 State v.”
State v. Wilson, 406 N.W.2d 123 (Neb. 1987). · cites it 2× “Neb. Rev. Stat. § 27-805 (Reissue 1985) provides: “Hearsay included within hearsay is not excluded under the hearsay rule if each part of the combined statements conforms with an exception to the hearsay rule proved in these rules.”
State v. Walker, 29 Neb. Ct. App. 292 (Neb. Ct. App. 2020). · cites it 2× “As to the statement of Walker herself within that report constituting hearsay within hearsay, Neb. Rev. Stat. § 27-805 (Reissue 2016) provides that “[h]earsay included within hear- say is not excluded under the hearsay rule if each part of the combined statements conforms with…”
State v. Edwards, 28 Neb. Ct. App. 893 (Neb. Ct. App. 2020). · cites it 2× “” Neb. Rev. Stat. § 27-805 (Reissue 2016). When an out-of-court statement relates the content of another out-of-court statement, there must be an independent hearsay exception for each statement.”
State v. Ramos, 319 Neb. 511 (Neb. 2025). · cites it 2× “2024) (defining hearsay); Neb. Rev. Stat. § 27-805 (Reissue 2016) (defining double hearsay).”
Carmela H. v. Luke S. (Neb. Ct. App. 2026). · cites it 2× “See Neb. Rev. Stat. § 27-805 (Cum. Supp. 2022).”
State v. Crouse (Neb. Ct. App. 2026). · cites it 2× “See, also, Neb. Rev. Stat. § 27-805 (Reissue 2016). In other words, when an out-of-court statement relates the content of another out-of-court statement, there must be an independent hearsay exception for each statement.”
State v. Stricklin (Neb. 2015). · cites it 2× “As an initial matter, to qualify as a statement against penal interest under rule 804(2)(c), the statement must be self-inculpatory.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.