United States v. Liera-Morales, No. 12-10548 (9th Cir. 2014)
Annotate this CaseDefendant appealed his convictions stemming from his involvement in a scheme to kidnap for ransom Franklin Aguilar-Avila. The court held that the district court's admission of a government agent's testimony recounting Franklin's mother's description of a telephone call with human traffickers did not violate the Confrontation Clause because the challenged statements from the telephone call were nontestimonial and their introduction at trial did not violate defendant's Confrontation Clause rights. Further, even if the principle underlying the Rule of Completeness (Rule 106) extended to the statements at issue here, the district court did not abuse its discretion in refusing to admit portions of the interview. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal Law. The panel affirmed convictions stemming from the defendant’s participation in a scheme to kidnap for ransom Franklin Aguilar-Avila, in a case in which the defendant was part of a human-trafficking ring that contacted Aguila-Avila’s mother, Sonia Avila, to demand payment for her son’s release. The panel held that the district court’s admission of a government agent’s testimony recounting Avila’s description of the telephone call in which she arranged for the safe return of her son did not violate the Confrontation Clause of the Sixth Amendment because the call was made primarily to address an ongoing emergency and the challenged statements were nontestimonial. The panel held that even if the Rule of Completeness applies, the district court did not abuse its discretion in admitting a government agent’s testimony about portions of the defendant’s post-arrest interview but precluding the defendant from introducing exculpatory statements from that interview.
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