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State v. Samuel Maduro

Vermont Supreme Court

816 A.2d 432 (2002)

Relevant factsFree

The State of Vermont (plaintiff) prosecuted Samuel Maduro (defendant) for conspiring with K.M., a minor, to sell cocaine and for delivering cocaine to her. At trial, the judge admitted testimony from Keith Merrow that he repeatedly went to Maduro's apartment in the same period to obtain cocaine for his own separate customers, who never accompanied him and were unknown to Maduro; Merrow once saw an unidentified girl in the apartment but she neither participated in nor witnessed any drug transaction between him and Maduro. The jury was instructed it could consider Merrow's testimony as bearing on both counts against Maduro, who was convicted and appealed, arguing Merrow's testimony related to a separate, uncharged conspiracy and was therefore inadmissible.

IssueFree

Whether evidence of a defendant's participation in related conspiracies is admissible to prove his participation in the conspiracy for which he is charged.

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