Dying Declaration Exception Still Alive and Well in Virginia.

Yesterday, in the case of Satterwhite v. Commonwealth, the Virginia Court of Appeals, in a published opinion, reaffirmed the existence of the dying declaration exception to the hearsay rule by permitting statements by a shooting victim (who died from his injuries) to his girlfriend into evidence during a murder trial.  Unfortunately, I could see this exception come into play in some domestic or criminal cases I work on given the high incidence of domestic violence.