State v. Stevens
In State v. Stevens, 171 Wis. 2d 106, 490 N.W.2d 753 (Ct. App. 1992), Strzyzewski testified that while she and Stevens were walking to school, Stevens said her stepfather told her that he had stolen some stereo equipment.
Strzyzewski then testified that she saw new stereo equipment at the Stevens' house less than a month later. We concluded that the circuit court erred in admitting this testimony because the recent perception exception to hearsay did not apply to "the aural perception of an oral statement privately told to a person." See id. at 119, 490 N.W.2d at 759.
The Court reasoned that corroboration was "the key to reliability" of a statement that falls under this exception, and that events are subject to corroboration because generally there will be no doubt that an event occurred, whereas statements or conversations are not subject to corroboration in a similarly objective fashion. See id. at 119, 490 N.W.2d at 759-60.