United States v. Rodriguez-Soriano, No. 18-4291 (4th Cir. 2019)
Annotate this CaseThe Fourth Circuit reversed defendant's conviction for knowingly making a false statement to a licensed firearms dealer in the acquisition of a firearm. The court held that it need not determine whether the expert testimony at issue was properly excluded because the evidence introduced at trial was insufficient to independently corroborate defendant's confession. Consequently, without the necessary corroboration of the confession, the prosecution failed to present sufficient independent evidence that a crime was committed, and where, as here, the prosecutor's failure to do so was "clear," the absence of substantial independent evidence cannot sustain the jury's verdict and required reversal. The court remanded with instructions to enter a judgment of acquittal.
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