Michael Turner, an undercover FBI agent, arranged a meeting to buy heroin from Clara Onaiwu. Turner recorded the meeting with a hidden tape recorder. Florence Obayagbona (defendant) was also present at the meeting. Obayagbona was charged with conspiracy to sell heroin. According to Turner’s testimony at trial, Obayagbona had handed Turner a sample of heroin from her purse. When the transaction was complete, other FBI agents swarmed in, and chaos ensued. Onaiwu, Obayagbona, and Turner were all arrested. After Turner was separated from Onaiwu and Obayagbona, and while Turner’s recorder was still recording, Turner’s fellow agents asked him about the heroin. On the recording, Turner stated that Obayagbona had handed him the sample, and his voice was exultant. The statement came approximately 14 minutes after Obayagbona handed the sample to Turner and two minutes after the arrest. The trial court admitted the recorded statement into evidence over Obayagbona’s objection. Obayagbona was convicted. Obayagbona appealed.