United States v. Pheaster

Pheaster was implicated in the kidnapping of Larry Adell, the 16-year-old son of Palm Springs multi-millionaire Robert Adell. Larry's friend testified at trial that Larry said he was going to meet Angelo, another defendant involved in the kidnapping. The trial court admitted the statements under the Hillmon doctrine. The Hillmon doctrine is a variant of the "state of mind" exception to the hearsay rule. The "state of mind exception" allows hearsay evidence if the state of mind of the declarant is an issue in the case. Under the Hillmon doctrine, "the state of mind of the declarant is used inferentially to prove other matters which are in issue," that "when the performance of a particular act by an individual is an issue in a care, his intention (state of mind) to perform that act may be shown. From that intention, the trier of face may draw the inference that the person carried out his intention and performed the act." The issue in this case related to the scope of the Hillmon doctrine - whether hearsay evidence is still admissible under Hillmon when it relates to an action that requires the action of one or more others to be fulfilled.

The Hillmon doctrine permits hearsay evidence when it relates to an action that requires the action of one or more others to be fulfilled.

The Hearsay Rule | Hearsay Exceptions | State of Mind