Ryan John Sanders, Petitioner v. State of Alaska, Respondent

Summary

The court held that statements recounting the victims’ plan to confront and assault Sanders were admissible under the state-of-mind and residual hearsay exceptions. It concluded that the lower courts applied an improperly demanding Confrontation Clause reliability standard and improperly excluded corroborating evidence when evaluating the defendant’s proffer. Because the excluded evidence was central to Sanders’s self-defense and related theories and the error was not harmless, the court reversed the convictions and remanded for a new trial.