State v. Castaneda, 215 N.C. App. 144

December 23, 2007, in Charlotte, Castaneda and others fight with Aguilar after a dispute over a grill; Aguilar is stabbed eight times front and seven times back and dies.
Castaneda fled the scene and state for seven months before arrest on July 31, 2008; detectives interview Castaneda with videotaped transcript.
Castaneda was charged with first-degree murder; he testified in his defense claiming self-defense against Aguilar's knife attack.
Trial court admitted a police interview transcript with non-testifying third-party statements without redaction; detectives commented that Castaneda lied.
Jury convicted Castaneda of second-degree murder; sentencing within presumptive range (151–191 months).
On appeal, the court held no error in admission of challenged transcript statements, and the conviction stands as supported by overwhelming evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detectives' statements about others' statements were hearsay.	State argues statements were not offered for truth.	Castaneda argues hearsay prohibition applies.	No hearsay error; statements offered for context and interviewing technique.
Whether admission of detectives' statements violated the Confrontation Clause.	Statements not offered to prove truth but to provide context.	Violation because they questioned credibility.	No Confrontation Clause violation; statements used to provide context.
Whether redaction of officers' statements accusing lies was required.	Redaction not required; context remains.	Redaction needed to prevent improper opinion evidence.	Admissible; context supports defendant's responses; no reversible error.
Whether admission of interrogators' statements about lying risked unfair prejudice.	Contextual relevance outweighs prejudice.	Potential prejudice should have excluded.	Not an abuse of discretion; evidence admissible in context.
Whether any error was harmless given overwhelming evidence of guilt.	Error would be prejudicial.	Overwhelming evidence renders any error harmless.	Harmless beyond a reasonable doubt; no reversal.

State v. Call, 349 N.C. 382 (1998) (hearsay framework for out-of-court statements offered for purposes other than truth)
State v. Coffey, 326 N.C. 268 (1990) (out-of-court statements admissible if not offered for truth)
Long v. Paving Co., 47 N.C.App. 564 (1980) (non-hearsay rationale for contextual statements)
State v. Miller, 197 N.C.App. 78 (2009) (limits on admissibility; use of statements to explain defendant's responses)
Boggs v. State, 218 Ariz. 325 (2008) (interrogation technique allowing lying accusations to provide context)
Cordova v. State, 137 Idaho 635 (2002) (interrogation statements admissible for context if relevant to answers)
Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005) (interrogation comments that suspect is not truthful as context, not impeaching witness)