Wassillie v. State

Summary

The court held that a halfway-house incident report was inadmissible hearsay because it lacked the trustworthiness required for the business-records exception, particularly where it was prepared during an investigation and incorporated information from a potentially biased source. Because the report supplied the only factual basis for the grand jury's escape indictment, the indictment was invalid, and the later error-free trial did not cure the defect. The court declined to overrule its precedent requiring reversal of a conviction based on an invalid indictment.