United States v. Jackson, No. 11-4858 (4th Cir. 2013)
Annotate this CaseDefendant was convicted of murder and various drug and firearm offenses in connection with a drug distribution conspiracy. On appeal, defendant argued that the forfeiture-by-wrongdoing exception to the Confrontation Clause, upon which the district court relied in admitting the victim's statement, did not apply unless a criminal defendant's sole motivation in making a witness unavailable was to prevent that witness's testimony. The court held however, that so long as a defendant intended to prevent a witness from testifying, the forfeiture-by-wrongdoing exception applied even if the defendant also had other motivations for harming the witness. Accordingly, the court affirmed the judgment.
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