United States Fourth Circuit

In appeal of murder and related convictions, judgment is affirmed, where: 1) so long as a defendant intends to prevent a witness from testifying, the forfeiture-by-wrongdoing exception to the Confrontation Clause applies even if the defendant also had other motivations for harming the witness; and 2) the district court's finding that preventing the witness from testifying was a "precipitating" and "substantial" reason why defendant murdered him, was sufficient to permit the admission of the witness' out of court statement pursuant to the forfeiture-by-wrongdoing exception to the Confrontation Clause.

Appellate Information

• Decided 01/18/2013
• Published 01/18/2013

Judges

• WILKINSON

Court

• United States Fourth Circuit

Counsel