State v. Hamilton

Summary

The court reversed the defendant’s convictions and remanded for a new trial because the trial court improperly admitted the state witness’s recorded police interviews as prior inconsistent statements without an adequate foundation showing inconsistency or refusal to testify. The error was harmful because the interviews supplied the principal identification evidence and were heavily emphasized in closing argument. The court also held that unequivocally adopted statements may qualify as a witness’s prior inconsistent statements, but the trial court—not the jury—must determine which statements were actually adopted; it upheld admission of the defendant’s social-media photographs and video. No separate opinions were filed.