State v. Lasecki

90 Ohio St. (N.S.) 10
CourtOhio Supreme Court
DecidedFebruary 24, 1914
DocketNo. 14280
StatusPublished

This text of 90 Ohio St. (N.S.) 10 (State v. Lasecki) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Lasecki, 90 Ohio St. (N.S.) 10 (Ohio 1914).

Opinion

Wanamaker, J.

Was the exclamation of the boy competent testimony?

Both sides agree that this is the only question in the case, and that the testimony is competent only upon the theory that it is a part of the res gestae of the case.

The record discloses that the exclamation arose ■in the following manner:

“Q. You may tell if anything unusual happened there and what it was, anything out of the ordinary? A. We was walkiiig about one hundred and fifty feet from the car, maybe two hundred, I "couldn’t tell you, and I heard the hitting twice, like 'that (indicating), and think there was an argument started and the boy said that the bums had killed his papa with a broomstick. Objection. Objection overruled. Exception.”

It will be noted that there was no objection to [13]*13the question, and that the objection is to the whole ■;a'nswer.

Now, manifestly, the major part of the answer is competent and responsive to. the question. If the .exclamation of the boy be incompetent, the objection of counsel should have been addressed to that exclamation, asking an order from the court to ex.clude it from the consideration of the jury. But that was not done. Where objection is made to the entire answer, part of which is competent and part incompetent, there is but one thing for the trial judge to do, that is to overrule the objection, and in this case there was no error on the part of the trial court.

But we are not disposed to decide a case of this importance upon the mere failure of counsel to properly save his rights, and shall consider the case on its merits, as if the objection and exception had (been properly made.

Was the exclamation a part of the res gestae f

Wharton’s definition of res gestae is as follows: “Those circumstancés which are the undesigned incidents of particular litigated acts, and are admissible where illustrative of such acts. These incidents may be separated from the act by lapse of time more or less appreciable. Their sole distinguishing feature is that they should be necessary incidents of the litigated act—necessary in this sense: ■that they are part of the immediate preparations for, or emanations from, such acts, and are not produced by the calculated policy of the actors. In ■other words, they must stand in immediate causal relation to the act—a relation not broken by indi[14]*14vidual wariness seeking to manufacture evidence for itself. Therefore declarations which are the immediate accompaniments of an act are admissible as part of the res gestae; remembering that immediateness is tested by closeness, not of time but by causal relation, o? just explained.” 7 Words and Phrases Judicially Defined, 6130.

Again, Wharton says res gestae are the facts which form the environment of a litigated issue.

Bishop, in his New Criminal Procedure (2 ed.), Section 1085, uses the following: “But it is difficult, perhaps impossible, to formulate an available rule as to what shall be deemed of the transaction, and what shall not. It appears safe to say that the subsidiary act neéd not transpire at the same instant with the main one, or always even on the same day; and, in reason, as well as in accordance with the current of the authorities, the time which divides the two is not the controlling consideration, though it may be taken into the account. Is it presumable that, distinctly and palpably, it influenced or was influenced by the main act, or proceeded from the same motive ? If so, it is admissible, otherwise not.”

Again, the same author, in Section 1086, uses this language: “The admissibility■ of particular acts being conceded, whatever of a nature explanatory thereof was during their performances said, whether by the doers or by the lookers-on, by the parties to the litigation, or by third persons, may, subject to some apparent or real qualifications, be given in evidence whenever the acts are. * * * In a general sense, the declarations from whatever [15]*15source must, to be thus admissible, be contemporaneous with the act they would illustrate. We may have cases apparently requiring them to be strictly so. But it is, at least, the better doctrine that they are competent whenever near enough to the act either before or after it, to be probably prompted by the same motive, not an afterthought, and apparently to constitute of it a part; otherwise they are not competent.”

Professor Wigmore, in his excellent work on Evidence, Vol. 3, Sections 1745 to 1747, discusses this same question with large ability and logical analysis, showing the foundation of the principle in the doctrine of res gestae as applicable to exclamations and as constituting a striking exception to the hearsay rule.

In Section 1747 the author uses this language: “This general principle is based on the experience that, under certain external circumstances of physical shock, a stress of nervous excitement may be produced which stills the reflective faculties and removes their control, so that the utterance which then occurs is a spontaneous and sincere response to the actual sensations and perceptions already produced by the external shock. Since this utterance is made under the immediate and uncontrolled domination of the senses, and during the brief period when considerations of self-interest could not have been brought fully to bear by reasoned reflection, the utterance may be taken as particularly trustworthy (or, at least, as lacking the usual grounds of untrustworthiness), and thus as expressing the real tenor of the speaker’s belief as to. [16]*16the facts just observed by him; and may therefore be received as testimony to those facts. The ordinary situation presenting these conditions is an affray or a railroad accident. But the principle itself is a broad one. , Its phrasings differ widely in different courts; but there is in the judicial opinion of to-day something of an approach to uniformity.”

The author cites a large number of cases in support of the doctrine.

It is impossible to reconcile the multitude of divers decisions by courts of last resort on the proper scope and limitations of the old phrase res gestae. Many of the states follow reverently and .rigidly the old English rule, that before any exclamation is admissible in evidence on the theory of res gestae, it must be contemporaneous in time with the principal fact in litigation. That is, just as soon as it appears that it is subsequent in time to the principal fact and merely narrative of it, such .exclamation is not a part of the res gestae and is, therefore, not admissible.

This old English rule had its birth in a strange combination of circumstances. First, the inhumanity and barbarity of the penalties provided by the .English law for criminal cases. A century ago two hundred crimes in England were punishable by death. Second, the prisoner had no rights in an English court of justice, save the right to be convicted. He was not competent as a witness in his .own behalf, nor indeed were any members of his family. He was not allowed the privilege of having his own counsel address the jury, and indeed, in earlier days, was not even allowed the privilege of [17]*17counsel. He had no right of appeal, and many other prerogatives now enjoyed by the defendants were wholly unknown to the English law a century or more ago.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kirk v. State
73 Ga. 620 (Supreme Court of Georgia, 1884)
Grant v. State
53 S.E. 334 (Supreme Court of Georgia, 1906)
Lander v. People
104 Ill. 248 (Illinois Supreme Court, 1882)
State v. William
105 N.W. 265 (Supreme Court of Minnesota, 1905)

Cite This Page — Counsel Stack

Bluebook (online)
90 Ohio St. (N.S.) 10, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lasecki-ohio-1914.