Supreme Court of Delaware

Urquhart v. State

February 26, 2016

Summary

The Supreme Court of Delaware affirmed Urquhart’s convictions, holding that an unidentified witness’s description of the getaway vehicle and license plate was admissible under the present-sense-impression and excited-utterance exceptions to the hearsay rule. The Court also held that the statement was nontestimonial because it was made voluntarily during an ongoing emergency and therefore did not violate the Confrontation Clause.