United States v. Valquier, No. 18-1636 (8th Cir. 2019)Annotate this Case
The Eighth Circuit affirmed defendant's conviction for conspiring to distribute methamphetamine. Even assuming that it was error to allow an officer to testify regarding defendant's pre-Miranda statements and actions, the admission of the testimony did not violate defendant's substantial rights. In this case, the officer testified that defendant gave a false explanation for his presence and hung his head in an apparent show of defeat at having been caught. The court rejected defendant's alleged Confrontation Clause violations, because any violation would not have posed a reasonable probability of altering the outcome of the trial and were not plain error.