R.I. Gen. Laws
Rhode Island General Laws

R.I. Gen. Laws § 14-1-69 (2026)

Hearsay

✓ current as of July 2026
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In any custody and/or termination trial and/or a hearing on a motion or probable cause hearing where a petition has been filed by the department of children, youth, and families in accordance with §§ 14-1-11, 40-11-7 and/or 15-7-7 in the family court, the court may, in its discretion, permit as evidence any statement by a child under the age of thirteen (13) years old about a prescribed act of abuse, neglect, or misconduct by a parent or guardian, if that statement was made spontaneously within a reasonable time after the act is alleged to have occurred, and if the statement was made to someone the child would normally turn to for sympathy, protection, or advice.

Notes of Decisions
Cited in 18 cases (2 in the last 5 years), 1988–2025 · leading case: In Re Alexis L., 972 A.2d 159 (R.I. 2009).
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In Re Alexis L., 972 A.2d 159 (R.I. 2009). · cites it 15× “Both DCYF and Alexis’s guardian ad litem argued that the child’s purported statements to his foster mother were admissible under G.L. 1956 § 14-1-69. Although the trial justice stated he would take the objection under advisement, immediately thereafter he permitted the foster…”
In re Emilee K. In re Jennifer K, 153 A.3d 487 (R.I. 2017). · cites it 11× “Among the enumerated errors are claims that the Family Court justice erred: (1) in allowing Bout-in-Gammon, a nonexpert evaluator, to testify in DCYF’s case in chief; (2) in construing G.L. 1956 § 14-1-69 as permitting the out-of-court statements of Jennifer to be introduced,…”
In Re Jessica C., 690 A.2d 1357 (R.I. 1997). · cites it 9× “In overruling respondent’s objection to the admission of these statements, the trial justice determined that this evidence was admissible under § 14-1-69. Section 14-1-69 provides: “Hearsay.”
In Re Nicole B., 703 A.2d 612 (R.I. 1997). · cites it 6× “At trial and again on appeal respondents insist that Nicole’s statements to Willis were inadmissible hearsay beyond the scope of the relevant exceptions to the hearsay rule, namely, Rule 803(4) of the Rhode Island Rules of Evidence and G.L.1956 § 14-1-69. Hearsay may be defined…”
In Re Jean Marie W., 559 A.2d 625 (R.I. 1989). · cites it 8× “1956 (1981 Reenactment) § 14-1-69, as enacted by P.L.1985, ch. 381, § 1.”
In Re Ne-Kia S., 566 A.2d 392 (R.I. 1989). · cites it 15× “1956 (1981 Reenactment) § 14-1-69, as enacted by P.L.1985, ch. 381, § 1, provides a sufficient independent basis for the admission of these statements.”
In re Rita F., 64 A.3d 1220 (R.I. 2013). · cites it 11× “The respondent objected to the admission of the testimony of Mainor and Ryan about the children’s statements, arguing that the statements were not admissible under the children hearsay exception of G.L.1956 § 14-1-69, because there was a lengthy passage of time between the…”
In Re Deborah M., 544 A.2d 572 (R.I. 1988). · cites it 6× “1956 (1981 Reenactment) § 14-1-69, as enacted by P.L. 1985, ch. 381, § l, 1 a statutory exception to the hearsay rule that applies to disputes involving custody and/or termination of parental rights.”
In Re Kristen B., 558 A.2d 200 (R.I. 1989). · cites it 2× “They allege error on two grounds: first, that the child’s competency was never established and, second, that her extrajudicial statements to Sandra Messier were not admissible under any recognized exception to the hearsay rule and otherwise lacked any special indicia of…”
In Re Veronica T., 700 A.2d 1366 (R.I. 1997). · cites it 6× “The trial justice admitted them into evidence pursuant to G.L.1956 § 14-1-69, which reads, in part, as follows: “In any custody and/or termination trial * * * the court may, in its discretion, permit as evidence any statement by a child under the age of thirteen (13) years old…”
Snowden v. State, 846 A.2d 36 (Md. Ct. Spec. App. 2004). “1 (2003); R.I. Gen Laws § 14-1-69 (2003); Utah Code Ann.”
In re Rocco W., 706 A.2d 1302 (R.I. 1998). · cites it 8× “Angelo and Duarte, should not have been admitted because those statements do not comply with the requirements of G.L. 1956 § 14-1-69. He argues that (1) the statements were not made spontaneously within a reasonable time after the alleged acts occurred and (2) they were not made…”
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