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United States v. Jackson | 335 F.3d 170 (2003)
In some cases, out-of-court statements that expose the declarant to criminal liability are admissible as an exception to the hearsay rule. But can those statements be admitted at a later trial to prove a coconspirator’s innocence? The Second Circuit considered this question in United States versus Jackson.
Charles Jackson and Steve Brown were charged with conspiracy to import five or more kilograms of cocaine. Brown pleaded guilty and signed a plea agreement stating that Jackson was one of several couriers he supervised. However, during his plea allocution, Brown denied supervising Jackson or asking him to smuggle cocaine.
At Jackson’s trial, the district court refused Jackson’s request to admit Brown’s statements into evidence, and the jury convicted Jackson. However, the district court granted his motion for acquittal as to the drug quantity and found him guilty of conspiracy to import between five hundred grams and five kilograms of cocaine. Jackson appealed his conviction to the Second Circuit. The prosecution filed a cross-appeal on the acquittal on drug quantity, arguing that a reasonable jury could’ve found that Jackson conspired to import at least five kilograms of cocaine.
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