Williamson v. US case brief

1. Williamson v. US (US 1994)
1. H makes both self-inculpatory and self-exculpatory statements; says that he wasn’t going to sell the cocaine, but that W was going to sell it; lower ct admitted evidence, W was convicted, and here appeals.
2. O’Connor for the ct: only those statements that are self-inculpatory, not neutral or exculpatory, should be admitted.
• interpretation doesn’t eliminate statements that mention a 3rd person.
• if declarant says, “Sam and I went to Joe’s house,” that is against interest if a reasonable person would believe that this would implicate him in S and J’s conspiracy; even in O’Connor’s view, reference to the other two would be against penal interest.
3. Kennedy concur: doesn’t agree with O’C that neutral statements should be excluded
• adding somebody doesn’t complicate the problem; it’s gratuitous.
• Kennedy’s gauntlet: what about collateral parts of exculpatory statements?  e.g., J is on trial for robbing bank, L makes statement “I robbed the bank alone” – is the “alone” part collateral?
4. Ginsberg dissent: none of this is a declaration against interest.
• all of H’s statements were made after arrest; he knew he had to cooperate and cut a deal to avoid significant jail time.