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United States v. Lopez-Medina

United States Court of Appeals for the Tenth Circuit
596 F.3d 716 (2010)


Facts

Lopez-Medina (defendant) and Lopez-Ahumado were charged with crimes involving methamphetamine. Lopez-Ahumado pleaded guilty, and during a hearing, he provided a factual allocution in which he admitted to the crimes along with Lopez-Medina. Lopez-Ahumado pleaded guilty following a deal with the government to obtain a reduced sentence if Lopez-Ahumado cooperated with the government in prosecuting others. Lopez-Ahumado did not cooperate with the government and did not obtain a reduced sentence. Lopez-Medina pleaded not guilty, and his defense was that the sole guilty party, Lopez-Ahumado, had already been convicted of the crimes. Lopez-Ahumado refused to testify at Lopez-Medina’s trial. Lopez-Medina sought to introduce Lopez-Ahumado’s conviction. The government argued that if Lopez-Ahumado’s conviction was admitted, then his fact allocution in which he stated he had committed the crimes jointly with Lopez-Medina should also be admitted even though it was hearsay. Lopez-Medina then sought to introduce evidence that Lopez-Ahumado had pleaded guilty as part of a deal with the government. The court held that the guilty plea, as well as the factual allocution, were admissible but that Lopez-Ahumado’s plea deal with the government was not. Following his conviction, Lopez-Medina appealed the admission of Lopez-Ahumado’s allocution.

Rule of Law

Issue

Holding and Reasoning (O’Brien, J.)

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