Tyquan Lucien was charged and jailed for making false statements to investigators when he claimed he did not know Dominque Mack (defendant) and others involved in murdering Charles Jernigan. Without realizing his cellmate was wearing a wire, Lucien told him “Big Mack. He want CJ gone.” The government recorded the statement and charged both Lucien and Mack in conspiring to murder Jernigan and another person who could help bring narcotics charges against Mack. Lucien pleaded guilty and cooperated with the prosecution in exchange for a lesser sentence, but Mack stood trial. Lucien testified that Mack had murdered one witness himself and had planned the murder of Jernigan. Mack claimed that Lucien falsely pinned blame on him because Lucien hated him and told anyone who would listen that Mack was responsible for Lucien’s crimes, and because Lucien knew he faced life in prison unless he substantially assisted the prosecution. Mack also challenged Lucien’s truthfulness based on the false statements he made to investigators that contradicted his testimony. To rehabilitate his credibility, the prosecution played the jailhouse recording of Lucien’s statement to his cellmate. The jury convicted Mack, and he appealed on various grounds, including the admission of the jailhouse recording.