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United States v. Estes

United States Court of Appeals for the Second Circuit
793 F.2d 465 (1986)


Facts

The United States government (plaintiff) prosecuted Kenneth Estes (defendant) for falsely testifying to a grand jury concerning his involvement in a theft. Estes' estranged wife Lydia Estes willingly testified before the grand jury and at trial that Kenneth brought a bag home and told her he stole the money the bag contained.  She then became Kenneth's accessory after the fact by helping count, hide, and launder the stolen money. After trial in the United States District Court for the District of Vermont, the jury convicted Kenneth Estes. On appeal to the United States Court of Appeals for the Second Circuit, Kenneth Estes argued all of Lydia Estes's grand jury and trial testimony involved confidential marital communications and should have been excluded.

Rule of Law

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Issue

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Holding and Reasoning (Van Graafeiland, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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