approved in Derrickson v. State, supra, there is nothing in the decision which indicates the demise of such requirements. Logic would seem to indicate that the five Derrickson foundational requirements of admissibility remain viable after Delaware’s adoption of its Uniform Rules of Evidence. This is so since such evidence can be most prejudicial unless safeguards are maintained. The scholarly opinion by Judge MacKinnon in United States v. Brown, 490 F.2d 758 (D.C.Cir.1973) highlights the need for a showing of substantial relevance before such evidence may be admitted: The threshold requirement of admissibility of such hearsay statements of fear of defendant in homicide cases is some substantial degree of relevance to a material issue in the case. While there are o.2d 811 (1983) (<HOLDING>). A case which, in my view, correctly reflects
holding inadmissible testimony dealing with the deceased victims fear of defendant where defendant claimed the victim had been accidently shot holding admissible testimony from 2 witnesses that within days immediately preceding the victims departure from kansas city with the defendant the victim stated that she feared that the defendant was going to kill her where the defendant claimed accident holding that case involving evidence such as eyewitness testimony placing the defendant at the scene acknowledgment by the defendant of a dispute with the victim and theft of the victims purse and dna evidence suggesting that the defendant had engaged in sexual relations with the victim could not be deemed entirely circumstantial holding admissible testimony of the victims daughter regarding a telephone call from the defendant to the victim hours before the victims death and the victims emotions following the telephone call where defendant claimed accident holding that the erroneous admission of a hearsay statement that identified the defendant as the shooter was harmless where the defendant never contested that he shot the gun but claimed only that he shot in selfdefense