Tuesday, December 24, 2013

United States v. Inadi case brief

United States v. Inadi case brief summary
475 U.S. 387 (1986)

CASE SYNOPSIS
On certiorari from the United States Court of Appeals, Third Circuit, petitioner challenged a ruling that reversed respondent's conviction for conspiracy to manufacture and distribute narcotics on grounds that a co-conspirator's out-of-court statements were improperly admitted into evidence, in violation of U.S. Constitutional Amendment VI and Fed. R. Evid. 801(d)(2)(E).

CASE FACTS
Respondent was convicted by a jury for conspiracy to manufacture and distribute narcotics. At trial, petitioner offered as evidence taped telephone conversations containing statements by a co-conspirator, who was subpoenaed by petitioner but failed to appear at trial. Over respondent's objections that the statements were inadmissible under Fed. R. Evid. 801(d)(2)(E) and that petitioner failed to show that the co-conspirator was unavailable to testify, in violation of the confrontation clause of U.S. Constitutional Amendment VI, the trial court admitted into evidence the out-of-court statements. The United States Court of Appeals for the Third Circuit reversed.

DISCUSSION
  • On certiorari, the Court reversed, holding that the confrontation clause did not require petitioner to show that a non-testifying co-conspirator was unavailable to testify, as a condition for admission of the coconspirator's out-of-court statements, when the statements satisfied Rule 801(d)(2)(E) in that that they were made in the course and in furtherance of the conspiracy.
CONCLUSION
Reversed; the Sixth Amendment's confrontation clause did not require petitioner to show that a nontestifying co-conspirator of respondent was unavailable to testify, as a condition for admission of the co-conspirator's out-of-court statements, so long as the statements were made in the course and in furtherance of the conspiracy.

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