Alvin E. Wassillie, Petitioner v. State of Alaska, Respondent.

Summary

The court held that a halfway-house incident report containing investigative hearsay was not admissible under the business-records exception because its preparation and sources lacked sufficient reliability. Because the report supplied the essential facts supporting the indictment, the indictment was invalid, and the defendant's later error-free trial did not render the grand-jury error harmless. The court declined to overrule its precedent requiring reversal of a conviction based on an invalid indictment.