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United States v. Rhynes

United States Court of Appeals for the Fourth Circuit
218 F.3d 310 (2000)


The United States government (plaintiff) prosecuted Michael Rhynes, D. S. Davis, and Corwin Alexander (co-defendants) for illegal drug dealing. Davis accepted the government's plea bargain and agreed to testify against Rhynes and Alexander. To ensure Alexander did not perjure his own testimony, the trial judge issued a Federal Rule of Evidence 615 sequestration order. The order prevented Alexander from hearing the details of Davis's testimony while Davis was on the witness stand. Davis's testimony revealed important details previously unknown to Rhyne's attorney, Scofield. Scofield briefed Alexander on Davis's revelations so Alexander could respond in his own testimony. After Alexander testified, Scofield told the judge about the briefing. The judge ruled Scofield violated the sequestration order and struck Alexander's testimony. The jury convicted Rhynes. Rhynes appealed to the United States Court of Appeals for the Fourth Circuit on the grounds it was reversible error for the judge to strike Alexander's testimony.

Rule of Law


Holding and Reasoning (King, J.)

Dissent (Wilkinson, C.J.)

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