Sunday, December 22, 2013

United States v. Owens case brief

United States v. Owens case brief summary
484 U.S. 554 (1988)

CASE SYNOPSIS
Defendant was convicted and sentenced to 20 years' imprisonment to be served consecutively to a previous sentence. On appeal, the United States Court of Appeals for the Ninth Circuit considered challenges based on the Confrontation Clause and Fed. R. Evid. 802. By divided vote, it upheld both challenges and reversed the judgment of the district court. The government appealed the judgment.

CASE FACTS
Defendant, who was already incarcerated, was accused of attacking an correctional counselor and brutally beating him with a metal pipe. The correctional counselor suffered a fractured skull that resulted in a loss of memory. However, the correctional counselor was able to identify the defendant but could not do so at the trial. The defendant was convicted and he appealed on the basis of theConfrontation Clause and Fed. R. Evid. 802 right to confrontation. The lower court upheld the defendant's challenges and the government appealed.

DISCUSSION

  • The Court reversed the judgment, holding that neither the Confrontation Clause nor Rule 802 was violated by admission of an identification statement of a witness who was unable, because of a memory loss, to testify concerning the basis for the identification. 
  • The Court found that successful cross-examination was not a constitutional guarantee. 
  • The Court noted that out-of-court statements were not inherently less reliable because of the possibility of suggestive procedures.
CONCLUSION
The Court reversed the lower court's judgment upholding the defendant's challenges to his conviction.


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