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236 Neb. 317

461 N.W.2d 253

State v. Plant

Nebraska Supreme Court

Decided October 5, 1990

Nebraska Supreme Court · decided 1990-10-05

Key passage — most relied on by later courts

“I concur because I believe the statements were admissible under Nebraska's residual hearsay exceptions in Neb.Rev.Stat. §§ 27-803(22) and 27-804(2)(e) (Reissue 1989) for the reasons set out in the majority opinion. I believe, however, that for this court to hold that the child's statements were "excited utterances" extends that doctrine to extraordinary and improper lengths.”

quoted by 1 later decision, including 1 Neb. Ct. App. 612 - State v. Tlamka

“key requirement is that the statement be made without time for conscious reflection.”

quoted by 1 later decision, including 1 Neb. Ct. App. 612 - State v. Tlamka

Applies NE 27 § 27-803

Relies on In Re Interest of RA

Good law ✅— No negative treatment on recordhow we know

Decided 1990-10-05

How this case has been cited

Cited by 77 later decisions — most recently May 2024 · most notably State v. Jacob (1998), State v. McBride (1996)

6 federal appellate · 69 state decisions

5401990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Grant, J.,

¶1concurring.

¶2I agree with the court’s decision affirming defendant’s convictions. I cannot agree with the court’s holding that the statements of 4-year-old Cindy Plant made to Officer Muldoon 2 days after the injuries inflicted by defendant on Christopher Bartlett, and concerning defendant’s conduct at the time of those injuries, were “excited utterances” and therefore admissible in evidence. I concur because I believe the statements were admissible under Nebraska’s residual hearsay exceptions in Neb. Rev. Stat. §§ 27-803(22) and 27-804(2)(e) (Reissue 1989) for the reasons set out in the majority opinion. I believe, however, that for this court to hold that the child’s statements were “excited utterances” extends that doctrine to extraordinary and improper lengths.

¶3The facts surrounding the child’s statements to the officer show conclusively, to me, that the child’s taped statements were not spontaneous and, therefore, not excited utterances. The child’s statements followed a 20-minute preliminary conversation between the officer and the child. The contents of that conversation are not before us, and we do not know what was said by either the child or the officer. It is undisputed that *344the conversation took place 2 days after the incident in question.

¶4I agree that the time interval is not controlling, see In re Interest of R.A. and V.A., 225 Neb. 157, 403 N.W.2d 357 (1987), but the interval should be considered. I also agree with the majority’s statement that “[t]he key requirement [to a determination of spontaneity] is that the statement be made without time for conscious reflection.”

¶5What I cannot agree with is the majority’s conclusion that the facts in this case permit the reception of the child’s taped statements as excited utterances. In this regard, the majority opinion states: “Cindy’s statements were made to a police officer, an authority figure commanding truthfulness. Related to this, the interview was conducted by one professionally trained in eliciting the truth from an interviewee.” In the circumstances in this case, I cannot see how statements elicited (and I do believe that is the appropriate word) from a 4-year-old child by a trained interviewer 2 days after an event could be spontaneous. I think we here stretch the excited utterance rule to the point where all utterances by a child may be admissible. I think that is wrong.

¶6Nonetheless, I concur because, as stated above, I believe there were appropriate other grounds for the admission of the child’s statements to the officer. Overwhelming other evidence pointed to the defendant’s guilt, including spontaneous statements of the same child to the physician who treated her.

Hastings , C. J., j oins in this concurrence.
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