Rule 2:805. Hearsay Within Hearsay

• Library: A Guide to the Rules of Evidence in Virginia (Virginia CLE) (2021 Ed.)

Rule 2:805. HEARSAY WITHIN HEARSAY

Hearsay included within hearsay is not excluded under the hearsay rule if each part of the combined statements conforms with an exception to the hearsay rule.

NOTES

The common law principle is that hearsay within hearsay is admissible if each statement conforms to the requirements of a hearsay exception. For example, in Eckhart v. Commonwealth, 222 Va. 213 (1981), the Supreme Court analyzed the trial court's ruling on multiple hearsay by separately considering each...