In re Ricky B

In In re Ricky B. (1978) 82 Cal. App. 3d 106, a witness testified he overheard a conversation between the defendant and another person, but denied the discussion concerned a stolen van. A police officer was permitted to testify that, prior to trial, the witness stated that during the overheard conversation, the defendant and his companion discussed having stolen a van. The court in In re Ricky B. ruled this multiple hearsay properly admitted because the witness's pretrial statement to the officer was a prior inconsistent statement and the overheard conversation constituted an admission or an adoptive admission by the defendant. (Evid. Code, 1220, 1221.)