In the minutes after a car accident, a very drunk man climbed out of the van that caused it, apologizing to his wife, and saying, "I didn't mean this. I didn't want to hurt you. I wasn't trying to hurt us." Meanwhile his wife, still stuck in the driver's seat, told the policeman who came to get her out that they had been fighting and her husband grabbed the wheel from her and veered into oncoming traffic to kill them both. Another witness heard the wife saying "I can't believe he did this. I don't know why he did this.", and the husband repeatedly apologizing.
At trial, the wife claimed the husband didn't grab the wheel -- she had just turned it too suddenly when she hit an unexpected bump. The trial court admitted her earlier statements as "excited utterances", and the Court of Appeals affirms, based on timing and spontaneity. Her statements were in the minutes after the accident, when she was not being questioned or asked to explain anything.
Synan v. Commonwealth, Va. Court of Appeals, published 1/24/17