context: "[R]egardless of whether the de-clarant is available at trial for cross-examination, a hearsay statement is not ordinarily admissible as substantive evidence."
citation_a.signal: no signal
citation_a.parenthetical: explaining the abrogation of the "Patterson Rule" that allowed admission of a declarant's out-of-court statement as substantive evidence so long as the declarant was available at trial for cross-examination
citation_a.sentence: Warren v. State, 725 N.E.2d 828, 835 n. 1 (Ind.2000) (explaining the abrogation of the “Patterson Rule” that allowed admission of a declarant’s out-of-court statement as substantive evidence so long as the declarant was available at trial for cross-examination); see also Appleton v. State, 740 N.E.2d 122, 124 (Ind.2001) (summarizing the evolution and problems with the Patterson Rule); Modesitt v. State, 578 N.E.2d 649, 652-654 (Ind.1991) (overruling the Patterson Rule and adopting Federal Rule of Evidence 801(d) that later became codified as Indiana Rule of Evidence 801(d)).
citation_b.signal: see also
citation_b.identifier: 578 N.E.2d 649, 652-654
citation_b.parenthetical: overruling the Patterson Rule and adopting Federal Rule of Evidence 801(d
citation_b.sentence: Warren v. State, 725 N.E.2d 828, 835 n. 1 (Ind.2000) (explaining the abrogation of the “Patterson Rule” that allowed admission of a declarant’s out-of-court statement as substantive evidence so long as the declarant was available at trial for cross-examination); see also Appleton v. State, 740 N.E.2d 122, 124 (Ind.2001) (summarizing the evolution and problems with the Patterson Rule); Modesitt v. State, 578 N.E.2d 649, 652-654 (Ind.1991) (overruling the Patterson Rule and adopting Federal Rule of Evidence 801(d) that later became codified as Indiana Rule of Evidence 801(d)).