United States v. Angleton

Robert Angleton (defendant) was on trial for the murder of his wife, Doris. In his defense, Robert claimed that Doris was murdered by his brother, Roger Angleton. In support, Robert sought to admit into evidence five handwritten notes that Roger wrote while in prison before committing suicide with painkillers and self-inflicted razor wounds. The notes were found in a plastic envelope on the floor of Roger’s jail cell, protected from Roger’s blood. Only one note of the five was dated, and that one was dated 16 days before Roger’s suicide. Three other notes contained no dates and no indication of when they were written. One note, to Vanessa Leggett, stated that Roger just took a load of painkillers and he was past the point of no return, but the handwriting was consistent, and the note was lengthy with several postscripts. The last note, addressed to Mark, contained shaky handwriting and said that Roger had taken painkillers to ease the pain from razor blades but contained no indication of when he took them or inflicted the fatal wounds. As to their content, the notes involved many matters not relating to Doris’s murder or Roger’s suicide. Four of the notes contained statements about Roger killing Doris and his inability to live with his guilt about the murder. The note to Mark, containing the shaky handwriting, stated that Roger killed Doris and that he felt very bad, among other things.