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Out of Court Statements Refuting Testimony, Not Proclaiming Guilt or Innocence, Admissible

Delaware state prisoner Jamil Edwards appealed his convictions for first degree murder and possession of a firearm during the commission of a felony. He claimed judicial abuse of discretion for disallowing refuting testimony. His convictions were overturned.

Robert Johnson, a rival drug dealer of Edwards, was murdered in 2004 and a grand jury indicted Edwards for the crime. Edwards’ cellmates, Michael Mude and Rachirie Garnette, appeared at his trial. As the prosecution's key witness, Mude testified that Edwards had admitted his guilt to him in front of Garnette; Garnette was not allowed to testify because the judge ruled that such testimony would be hearsay. Edwards was convicted and sentenced to death plus three years for the felonious weapon charge. He appealed.

The Supreme Court of the State of Delaware reversed the convictions due to judicial error. The Court ruled that since Garnette's testimony would have refuted Mude's testimony as to the out of court statements, and would not have proclaimed Edward's guilt or innocence, it was not hearsay and thus was admissible because there were no eyewitnesses to the crime. See: Edwards v. State of Delaware, 925 A.2d 1281 (Del.Supr. 2007).

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Related legal case

Edwards v. State of Delaware