United States v. Jackson

335 F.3d 170 (2003)

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United States v. Jackson

United States Court of Appeals for the Second Circuit
335 F.3d 170 (2003)

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  • Written by Sean Carroll, JD
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Facts

Charles Jackson (defendant) and Steve Brown were charged with conspiring to import cocaine. Brown agreed to a plea bargain. During Brown’s plea hearing, Brown pled guilty to the charges, but stated that he did not supervise Jackson as part of the conspiracy and did not ask Jackson to smuggle any cocaine. At Jackson’s trial, Jackson sought to introduce Brown’s statements into evidence. The district court declined to permit Jackson’s introduction of the statements. A jury convicted Jackson, who appealed.

Rule of Law

Issue

Holding and Reasoning (McLaughlin, J.)

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Casebooks

Evidence

Key Terms

  • Rule 804(b)(3) of the Federal Rules of EvidenceProvides that a statement that was against the declarant’s pecuniary or proprietary interest at the time he made it is admissible as an exception to the hearsay rule if the declarant is unavailable as a witness. In criminal proceedings, statements that incriminate an out-of-court declarant must be supported by corroborating circumstances that clearly indicate trustworthiness.
  • Federal Rule of Evidence 804(b)(1)An exception to the hearsay rule providing that former testimony of a witness is admissible if the witness is unavailable, and if the testimony is offered against a party who had, or whose predecessor in interest had, a similar motive and opportunity to develop the prior testimony through direct, cross, or redirect examination.
  • Guilty-Plea ColloquyAn inquiry by the court to a defendant to ensure that the defendant’s guilty plea to criminal charges is knowing, voluntary, and based upon facts sufficient to support a finding of guilt.

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