State v. Motta
Hawaii Supreme Court
659 P.2d 745 (1983)
Relevant factsFree
After being robbed at gunpoint, Wendy Iwashita described her attacker to a police artist who created a composite sketch, and she later identified Motta (defendant) from a photo array, at a preliminary hearing, and at trial. Motta presented an alibi defense with corroborating witnesses. The jury convicted him, and he appealed, arguing the composite sketch was inadmissible hearsay and improperly used to corroborate an unimpeached witness.
IssueFree
Whether a composite police sketch based on a witness's description is inadmissible hearsay.