United States v. Proano

912 F.3d 431 (2019)

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United States v. Proano

United States Court of Appeals for the Seventh Circuit
912 F.3d 431 (2019)

SC

Facts

Proano (defendant) was a police officer and was charged with civil-rights violations for his handling of an arrestee. The prosecution (plaintiff) called Snelling and Jamison as witnesses. Snelling and Jamison were police academy teachers at the time Proano was enrolled in the academy and testified to having given use-of-force training at the academy. The witnesses could not remember whether they had trained Proano specifically but testified that there was a common curriculum at the academy that maintained consistency across instructors. Proano was convicted. Proano appealed, arguing that Snelling and Jamison’s testimony should not have been admitted because the witnesses did not have personal knowledge of the training Proano received.

Rule of Law

Issue

Holding and Reasoning (St. Eve, J.)

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