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United States v. Dotson
United States Court of Appeals for the Fifth Circuit
821 F.2d 1034 (1987)
At the trial of Frederick Dotson (defendant), the prosecution (plaintiff) introduced a police report that stated that Sergeant Anderson had said that Young told Anderson that he dealt drugs for Dotson. Dotson argued that the report contained inadmissible hearsay. The district court admitted the report on the ground that Young’s statement was not hearsay but a prior consistent statement under Federal Rule of Evidence 801(d)(1)(B). Dotson was convicted, and United States Court of Appeals for the Fifth Circuit affirmed the conviction, ruling that the hearsay-within-hearsay principle contained in Federal Rule of Evidence 805 (Rule 805) did not apply to prior consistent statements under Federal Rule of Evidence 801(d)(1). Dotson filed a petition for rehearing.
Rule of Law
Holding and Reasoning (Per curiam)
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