United States Ninth Circuit

Defendant's convictions for his role in a scheme to kidnap for ransom are affirmed, where: 1) the district court's admission of a government agent's testimony recounting the victim's mother'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; and 2) 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.

Appellate Information

• Decided 07/21/2014
• Published 07/21/2014

Judges

• McKEOWN

Court

• United States Ninth Circuit

Counsel