Perry v. Haritos
In Perry v. Haritos, 100 Conn. 476, 124 A. 44 (1924), the Court recognized the spontaneous utterance exception to the hearsay rule. This exception allows otherwise inadmissible statements into evidence to prove the truth of the matter asserted if it is proven that:
(1) the declaration follows some startling occurrence;
(2) the declaration refers to the occurrence;
(3) the declarant observed the occurrence;
(4) the declaration is made under circumstances that negate the opportunity for deliberation and fabrication by the declarant.