Emmanuel Farris (defendant) was charged with conspiracy to commit robbery, among other things. His identification at the scene of the robbery was the main issue at trial. At trial, the prosecution asked a detective about his interrogation of Gary Moore, another man charged with the robbery. The prosecution asked the detective if Moore said anything to the detective and the detective said that he had. At this point, the defendant objected to the line of questioning. The trial court overruled the objection. The prosecution continued: “As a result of what Gary Moore told you, what if anything did you do?” The detective answered: “I arrested Emmanuel Farris.” The trial court found that the statement was not hearsay, but that the detective was merely describing the steps in his investigation. Moore did not testify at the trial. The trial court convicted Farris. He appealed on the grounds that the testimony was improperly admitted.