Thursday, December 5, 2013

United States v. Arnold case brief

United States v. Arnold case brief summary
486 F.3d 177 (2007)

Defendant challenged his felon-in-possession-of-a-firearm conviction under 18 U.S.C.S. § 922(g)(1), contending that the evidence did not support the verdict, that the United States District Court for the Western District of Tennessee at Memphis violated his Confrontation Clause rights by admitting testimonial hearsay, and that the district court made several erroneous evidentiary rulings during the course of the trial.


  • The court held that a rational trier of fact could have concluded beyond a reasonable doubt that defendant possessed a gun where there was evidence that: 
  • (1) defendant and a victim began arguing and that during the argument defendant retrieved a gun and pointed it at the victim as she fled to call the police; 
  • (2) the victim described the gun to officers as a black handgun; 
  • (3) the way the victim described defendant's cocking the weapon indicated to the officers that it was a loaded semiautomatic with a round of ammunition in its chamber; 
  • (4) moments later, a car containing defendant arrived at the scene and the police found a gun inches from where defendant was sitting; and 
  • (5) the gun in every way matched the victim's description: black, semiautomatic, and with a round in its chamber. 
  • Because the victim's statements to a 911 operator, and to police both when they first arrived at the scene and when defendant first appeared on the scene were non-testimonial and because defendant had not shown that the admission of the statements violated the Federal Rules of Evidence, specifically Fed. R. Evid. 803(2), their admission did not violate the Confrontation Clause of the Sixth Amendment.

The conviction was affirmed.

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