Standard of review on appeal of admissibility of hearsay

R. v. Mullings, 2014 ONCA 895:

[28]       The standard of review on an appeal of a ruling on the admissibility of hearsay evidence is correctness: R. v. Duong, 2007 ONCA 68, 84 O.R. (3d) 515, at para. 54. As the respondent notes, however, this analysis is generally fact-specific and deference should be given to the trial judge's weighing of the factors going to the reliability of the statement. As this court observed in R. v. S.S., 2008 ONCA 140, 232 C.C.C. (3d) 158, at para. 30: 

As long as the trial judge addressed the factors germane to the reliability of the hearsay statement, did not fall into any material misapprehension of the evidence relevant to those factors, and made a reasonable assessment of the weight to be assigned to those factors, this court should not redo the weighing process, but should defer to the trial judge's weighing of those factors.

See also: R. v. Carroll, 2014 ONCA 2, 304 C.C.C. (3d) 252, at para. 112, leave to appeal to S.C.C. refused, [2014] S.C.C.A. No. 193.