United States v. Adams
United States Court of Appeals for the Tenth Circuit
271 F.3d 1236 (2001)
Dale L. Adams (defendant) was tried and convicted for possession of a firearm by a felon. The United States government (plaintiff) based much of its case on incriminating statements Adams made after his arrest. Prior to a hearing that took place shortly before trial, Adams faxed an expert psychological report to the trial judge. The report cast doubt on the reliability of Adams's incriminating statements, given Adams's psychological characteristics. Introduction of this report might have supported Adams's later trial testimony, in which he denied the truth of his incriminating statements. The report was not marked as an exhibit and never became part of the trial record. The judge referred to the report at the pretrial hearing and refused to allow its introduction at trial. At trial, Adams argued the excluded report would support his testimony and again sought to admit the report into evidence. The government objected and the judge rejected the offer of proof. Adams appealed his conviction to the United States Court of Appeals for the Tenth Circuit. Adams contended rejection of his offer of proof deprived him of due process and a fair trial. Adams moved the appellate court to accept the proffered report as a supplement to the trial record and the government did not object.
Rule of Law
Holding and Reasoning (Kelly, J.)
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