Legal Definitions - state-of-mind exception

The state-of-mind exception is a legal principle that allows certain out-of-court statements to be admitted as evidence in court, even though they would typically be excluded under the general rule against hearsay.

Hearsay refers to an out-of-court statement offered in court to prove the truth of the matter asserted. Generally, hearsay is not admissible because the person who made the statement (the "declarant") cannot be cross-examined in court. However, the state-of-mind exception permits the admission of a declarant's out-of-court statement if it reveals their then-existing mental, emotional, or physical condition, such as their intent, plan, motive, or feeling. The statement must reflect the declarant's state of mind at the time the statement was made, not a past state of mind.

Here are some examples illustrating the state-of-mind exception:

• Example 1: Expressing Intent or Plan

  Imagine a civil lawsuit where a plaintiff claims they were supposed to meet a business partner, Mr. Henderson, for a crucial negotiation, but Mr. Henderson never showed up. The day before the meeting, Mr. Henderson told his assistant, "I'm flying to London tomorrow morning to finalize the deal with Acme Corp." Mr. Henderson then disappeared and cannot be located to testify. The assistant's testimony about Mr. Henderson's statement could be admitted under the state-of-mind exception.

  Explanation: Mr. Henderson's statement, "I'm flying to London tomorrow morning," is an out-of-court declaration of his then-existing plan or intent. It is offered to show that he intended to go to London, which explains his absence from the negotiation. Even though it's hearsay, it's admissible because it directly reflects his state of mind (his plan) at the time he made the statement.

• Example 2: Expressing Emotional Condition

  Consider a divorce case where one spouse alleges emotional abuse. A friend of the spouse testifies that, a week before filing for divorce, the spouse called her crying and said, "I'm so terrified to go home tonight; I feel completely trapped and helpless." The spouse is now unavailable to testify due to severe illness.

  Explanation: The spouse's statement, "I'm so terrified to go home tonight; I feel completely trapped and helpless," is an out-of-court statement reflecting her then-existing emotional state. It is offered to show her fear and feelings of entrapment at that specific time, which is relevant to the claim of emotional abuse. This statement would likely be admissible under the state-of-mind exception because it directly conveys her current emotional condition.

• Example 3: Expressing Motive or Purpose

  In a criminal trial for theft, the defense argues that the accused, Ms. Davies, had no reason to steal from her employer. However, a colleague testifies that a few days before the alleged theft, Ms. Davies confided in her, saying, "I'm desperate for money to pay my mother's medical bills, and I don't know what else to do." Ms. Davies later invoked her Fifth Amendment right not to testify.

  Explanation: Ms. Davies's statement, "I'm desperate for money to pay my mother's medical bills," is an out-of-court declaration that reveals her then-existing financial motive or purpose. It is offered to show that she had a strong financial need, which could be relevant to establishing a motive for the alleged theft. Despite being hearsay, it is admissible because it directly communicates her current state of mind regarding her financial desperation.