United States v. Urias Espinoza, No. 16-50033 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit reversed defendant's conviction for importation of methamphetamine, holding that the district court necessarily abused its discretion because it applied the wrong legal standard in excluding the evidence of third-party culpability for failing to meet the "substantial evidence" threshold in Perry v. Rushen, 713 F.2d 1447 (9th Cir. 1983), and Territory of Guam v. Ignacio, 10 F.3d 608 (1983). The panel held that nothing in Perry purported to import California's evidentiary standard, and nothing in Ignacio purported to announce a new rule for the admissibility of third-party culpability evidence under the Federal Rules of Evidence. Because the district court's error was not harmless, the panel remanded for a new trial.
Court Description: Criminal Law. The panel reversed a conviction for importation of methamphetamine and remanded for a new trial in a case in which the district court excluded evidence of third-party culpability. The panel held that the district court necessarily abused its discretion by applying an incorrect legal standard when it excluded evidence of third-party culpability for failing to meet the “substantial evidence” threshold discussed in Perry v. Rushen, 713 F.2d 1447 (9th Cir. 1983), and Territory of Guam v. Ignacio, 10 F.3d 608 (1983). The panel explained that nothing in either Perry or Ignacio purports to modify this court’s standard for the admissibility of third-party culpability evidence under the Federal Rules of Evidence—“fundamental standards of relevancy.” Applying that standard, the panel held that the excluded evidence is undoubtedly relevant, and that a neighbor’s conviction documents were improperly excluded under Fed. R. Evid. 404(b). The panel concluded that the erroneous exclusion of evidence was not harmless. UNITED STATES V. URIAS ESPINOZA 3
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