Sunday, December 22, 2013

Williamson v. United States case brief

Williamson v. United States case brief summary
512 U.S. 594 (1994)

The United States Court of Appeals for the Eleventh Circuit affirmed defendant's conviction on three drug charges based in part on hearsay evidence of statements of a witness who refused to testify. Defendant sought review by certiorari.

Defendant was convicted of three drug charges. At trial, a witness whose testimony ultimately led to defendant's arrest, refused to testify despite being held in contempt.  The Court found that the witness was unavailable and admitted hearsay evidence by a police officer of the witness's statement that included statements incriminating him and defendant, under the exception to the hearsay rule for statements against the interest of the declarant. Defendant's conviction was affirmed on appeal.


  • The Court reversed, holding that the statements against interest of the declarant exception to the hearsay rule did not allow admission of non-self-inculpatory statements, even if they were made within a broader narrative that was generally self-inculpatory.

The Court vacated the judgment and remanded the case for further proceedings.

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