State v. Canady

In State v. Canady, 355 N.C. 242, 559 S.E.2d 762 (2002), the detective's "testimony provided more than a mere explanation of his subsequent actions. The detective provided details contained in the declarant's statement including how defendant broke into the victims' house through a window, went into the bathroom with a rifle, shot one of the victims, and fled with a bag of money." Canady, 355 N.C. at 249, 559 S.E.2d at 766 (2002). "Moreover, the State in Canady relied upon the detective's recitation of the declarant's detailed statement during the State's closing argument." Id. The Court in Canady concluded that "the State relied on the detective's testimony as substantive evidence of the details of the murders and to imply defendant had given a detailed confession of his alleged crimes." Id. The Court held that "by using the detective's testimony in this manner, the State undoubtedly sought to prove the truth of the matter asserted." Id.