P. v. Froste CA3
A jury found defendant David Ashley Froste guilty of first and second degree murder and kidnapping. He was sentenced to life in prison without the possibility of parole. On appeal, defendant raises three contentions: (1) the admission of certain hearsay statements, as a statement against interest, was error because the statements were not against the declarant’s penal interest and lacked indicia of reliability; (2) the trial court abused its discretion in refusing to hold an evidentiary hearing into possible juror misconduct; and (3) punishment for kidnapping must be stayed pursuant to Penal Code section 654. (Statutory section citations that follow are to the Penal Code unless otherwise identified.)
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