Bridges v. Clark, 59 A.3d 978 (2013)

Citation: Bridges v. Clark, 59 A.3d 978 (2013)
Parent Document: Bridges v. Clark, 59 A.3d 978 (2013)
Jurisdiction: DC (municipal)
Effective Date: 2013-01-24
Original Source: https://www.courtlistener.com/opinion/5146099/bridges-v-clark/ ↗

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. Ms. Bridges argues that this court should review de novo the trial court’s ruling excluding the affidavit, whereas Mr. Clark contends that this court’s review should be for abuse of discretion. This court’s cases do not provide clear guidance on that issue. See, e.g., In re K.J., 11 A.3d 273, 279 (D.C.2011) ("Evidentia-ry rulings by the trial court are reviewed for abuse of discretion!,] but ... determining whether a statement falls within an exception to the hearsay rule ... presents a question of law which this court considers de novo.”) (internal quotation marks omitted); Obelisk Corp. v. Riggs Nat'l Bank, 668 A.2d 847, 855 n. 7 (D.C.1995) (trial court acted within its "broad discretion” in finding that statement was not admission of party opponent). We need not resolve the issue. For the reasons explained in text, the ruling at issue was erroneous even if reviewed deferentially.

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