California, United States of America
The following excerpt is from People v. Sanchez, F064627 (Cal. App. 2014):
"In reviewing the trial court's order overruling the hearsay objection, we apply the deferential abuse of discretion standard of review." (People v. Fields (1998) 61 Cal.App.4th 1063, 1067.) Legal questions concerning the constitutionality of admitting the challenged evidence are reviewed de novo. (See People v. Seijas (2005) 36 Cal.4th 291, 304 [independent standard of review should be applied to rulings which affect the constitutional right of confrontation].)
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