People v. Noguera

In People v. Noguera (1992) 4 Cal.4th 599, the Supreme Court determined that certain out-of-court statements purportedly made by a murder victim about her fear of the defendant constituted inadmissible hearsay. ( Noguera, supra, 4 Cal.4th at pp. 620-621.) However, the court found that those errors did not require reversal. In so concluding, the court pointed out that the trial court gave a limiting instruction when the statements were introduced into evidence to the effect that they were only admissible to establish the victim's state of mind. The court also observed that the prosecutor repeated that limitation during closing argument. The court further noted that the case against the defendant was strong; thus, the "admission of the hearsay statements added little to a substantial case pointing to defendant's guilt." ( Id. at pp. 622-623.) The court continued: "For that reason also, we reject defendant's claims that admission of the victim's hearsay statements violated his rights secured under the confrontation clauses of the federal and California Constitutions. In light of the substantial evidence pointing to defendant's guilt, we conclude that the error in admitting the challenged hearsay statements was harmless beyond a reasonable doubt." ( Noguera, supra, 4 Cal.4th at p. 623.)