California, United States of America
The following excerpt is from People v. Velado, B279955 (Cal. App. 2018):
"We review a trial court's decision whether a statement is admissible under Evidence Code section 1230 for abuse of discretion. [Citations.] Whether a trial court has correctly construed Evidence Code section 1230 is, however, a question of law that we review de novo." (People v. Grimes (2016) 1 Cal.5th 698, 711-712 (Grimes).) Thus, "the application of the against-interest exception 'to the peculiar facts of the individual case' is reviewed for abuse of discretion" (ibid.), but a conclusion of law underlying the court's ruling is reviewed de novo.
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