4/4/16 Out of court statements are generally considered hearsay, and as such are inadmissible in a trial. An exception to that rule is the Present Sense Exception, which are statements people make of their observations as they are observing an event as it is happening. The idea is that people would not have time to think of fabrications if they are simultaneously observing something and describing it.
In State v. Wright, No. 2 CA-CR 2015-0222, police officers were recording themselves as they were working in an undercover operation. They were describing for example where people were walking. At trial the prosecutor used these recordings. The defendant was convicted of drug offenses with evidence seized by the police in the investigation. On appeal the defendant argued that the recorded statements were in effect a police report, and since police reports are inadmissible hearsay they should not have been admitted into evidence. In support of his argument the defendant cited a Texas DUI case in which the investigating officer recorded his statements as he conducted a DUI investigation. That DUI officer’s recordings were held to be inadmissible because he was not only recording his observations but also his conclusions. The Texas court said the statements were inadmissible because it was not simply a Present Sense statement but rather in effect an oral police report he was preparing for trial. In Wright, the Court of Appeals said the Texas case did not apply because in that case the recordings were in effect a police report prepared for possible trial. The Court of Appeals in Wright said that since the statements were not being prepared for trial they were admissible as Present Sense statements.
https://www.courtlistener.com/opinion/3188261/state-of-arizona-v-arthur-cornell-wright/
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