Estes v. State
In Estes v. State, 249 P.3d 313, 315 (Alaska App. 2011) the Court recognized that an out-of-court statement could be offered "to provide the foundation or context for understanding ... statements that the defendant made when she responded to ... assertions about what the declarant purportedly said."
The Court concluded that the probative aspect of such a statement was not whether the statement was true, but how the defendant responded to the assertion that the statement had been made.
The Court concluded that the jury could be apprised of how the disputed statements were characterized to the defendant, so that the jury could understand the defendant's response in context. (Id. at 315-16.)