People v. Kampas

Defendant was convicted of aggravated domestic battery and domestic battery of her 17-year-old daughter. No ineffective assistance of counsel in counsel failing to object to admission of daughter's written statement to the police as hearsay, as statement complied with each of the requirements of Rule 801(d)(1)(A)(2)(a), and thus is "not hearsay" and was properly introduced as substantive evidence. Written statement was inconsistent with daughter's testimony that she was the initial aggressor.(HOLDRIDGE and O'BRIEN, concurring.)