In Hamilton v. State, 771 P.2d 1358 (Alaska App. 1989), Hamilton faced sentencing for sexual assault in the first degree. The State sought to establish two aggravating factors to enhance Hamilton's sentence: that Hamilton had a prior criminal history of assaultive behavior and that Hamilton had committed prior similar offenses. The State offered the hearsay statements of two women who alleged that Hamilton had sexually assaulted them. Hamilton entered a testimonial denial that he had committed the sexual assaults. But the sentencing judge found the hearsay statements were sufficient to establish the aggravating factors. Hamilton appealed.