State v. Wargo
In State v. Wargo, 53 Conn. App. 747, 731 A.2d 768 (1999), aff'd, 255 Conn. 113, 763 A.2d 1 (2000), the defendant set his house on fire to hide the fact that he had killed his wife. More than ninety minutes after the fire had started, the defendant's children made statements implicating their father.
The Court stated that "the challenged statements were made while the children were under the stress of watching their house burn while their mother's condition was unknown." Id. at 757.
Specifically, the defendant's son stated that "his mother was in the house" and the defendant's daughter stated that "her father had stepped on her mother while he was getting the children out of the house." State v. Wargo, supra, 53 Conn. App. at 755. The defendant's son also stated that his parents had been fighting that night. Id.