Oklahoma Statutes
Okla. Stat. tit. 12, § 2805 (2026)
Hearsay within hearsay
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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 this Code. Added by Laws 1978, c. 285, § 805, eff. Oct. 1, 1978.
Notes of Decisions
Cited in 6
cases, 1987–2017 · leading case: Hanson v. State, 2009 OK CR 13, 206 P.3d 1020.
Hanson v. State, 2009 OK CR 13, 206 P.3d 1020. “Defense counsel argued that he should be allowed to question Detective Nance about Henry's conversation with Miller rather than calling Henry himself, stating in support that he did not know whether Henry would invoke his Fifth Amendment privilege if called to testify and argued…”
Ashton v. State, 2017 OK CR 15, 400 P.3d 887. “3d 1196, 1209 (quoting 12 O.S.2001, § 2805). ¶30 In the present case, Appellant has only shown that one part of the combined statements met an exception to the hearsay rule.”
Mitchell v. State, 2005 OK CR 15, 120 P.3d 1196. “" 12 O.S.2001, § 2805. Neither part of the referenced double hearsay statement fell within an exception to the hearsay rule.”
Jones v. State, 738 P.2d 525 (Okla. Crim. App. 1987). “See 12 O.S.1981, § 2805. See also 1 L. Whinery, Guide to the Oklahoma Evidence Code 311-13 (1985).”
Ashton v. State, 2017 OK CR 15. “3d 1196, 1209 ( quoting 12 O.S.2001, § 2805). ¶30 In the present case, Appellant has only shown that one part of the combined statements met an exception to the hearsay rule.”
Winkler v. State, 745 P.2d 1189 (Okla. Crim. App. 1987). “Second, the report did not meet the requirements of 12 O.S.1981, § 2805 which states: “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 this rule.”
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