Sunday, December 22, 2013

United States v. Oates case brief

United States v. Oates case brief summary
560 F.2d 45 (1977)

CASE SYNOPSIS
Defendant appealed from a judgment entered in the United States District Court for the Eastern District of New York, challenging the admission of evidence used to convict him on charges of possession of her*in with intent to distribute and conspiracy.

CASE FACTS
Defendant was convicted of possession of her*in with intent to distribute and conspiracy.

ISSUE
whether the trial court incorrectly admitted into evidence, under Fed. R. Evid. 803(8), the official report and worksheet of the chemist who analyzed the substance seized from defendant's co-conspirator.

DISCUSSION

  • The court held that, in criminal cases, reports of public agencies that set forth factual findings that resulted from investigations made pursuant to authority granted by law could not satisfy the standards of any hearsay exception if those reports were sought to be introduced against the accused. 
  • The court determined that, although the chemist's documents were critical to the prosecution's case, they were hearsay and ineligible to qualify for any exception to the hearsay rule. 
  • The court reversed and remanded because the admission of the chemist's report into evidence was prejudicial error against defendant.

CONCLUSION
The court reversed and remanded the lower court's decision because the admission of the chemist's report into evidence was prejudicial error against defendant where the report was hearsay and did not qualify under any exception to the hearsay rule.

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