United States v. Neadeau

639 F.3d 453 (2011)

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United States v. Neadeau

United States Court of Appeals for the Eighth Circuit
639 F.3d 453 (2011)

Facts

Marcus Neadeau (defendant) was arrested for conspiring to distribute crack cocaine and other alleged crimes. At Neadeau’s detention hearing, his wife, Vanessa Sagataw (defendant), testified on his behalf. Later, Sagataw was indicted and tried with Neadeau as his codefendant. At trial, Sagataw invoked her Fifth Amendment right to not incriminate herself and did not testify. The trial court admitted evidence of Sagataw’s detention-hearing testimony, finding that it was admissible as a prior inconsistent statement. Neadeau was convicted and appealed, arguing that Sagataw’s detention-hearing testimony was inadmissible hearsay.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

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