Termination of Parental Rights

82.09.h Rules of Evidence Article VIII-Hearsay

In Re L.C., L.C. and I.C., COA05-471, Peter Wood for appellant-father
Even if the documents were admissible under the business records exceptions, the statements of the minor children within the documents were still hearsay and not admissible.
COA Opinion

In Re J.S.B., D.K.B., D.D.J. and Z.A.T.J., COA06-1107, K. Edward Greene, Adrienne F. Allison for appellant-mother
The trial court erred in admitting a medical examiner's report and an autopsy report under the business records exception to the hearsay rules due to the lack of a proper foundation.
COA Opinion

In Re J.S.B., D.K.B., D.D.J. and Z.A.T.J., COA06-1107, K. Edward Greene, Adrienne F. Allison for appellant-mother
The trial court erred in admitting statements by the child to a police officer as it did not meet any recognized exception to the hearsay rules, including the 'excited utterance' exception.
COA Opinion

In Re S.D.J., COA08-360, Mary McCullers Reece for appellant-mother
The trial court erred when it admitted an unauthenticated letter to the social worker from a drug abuse treatment center and drug screen lab reports.
COA Opinion

In Re S.A.C., H.D., COA09-919, Leslie Rawls for appellant-mother
The trial court erred by admitting into evidence letters written by a non-testifying psychologist to the DSS caseworker.
COA Docket