United States v. Castro-Ayon
United States Court of Appeals for the Ninth Circuit
537 F.2d 1055 (9th Cir. 1976)
Rafael Castro-Ayon (defendant), a U.S. citizen, was stopped while driving a van carrying 11 undocumented immigrants, who were taken into custody and interrogated under oath about Castro-Ayon's role. Castro-Ayon was charged with inducing illegal immigration, transporting immigrants, and conspiracy. At trial, three of the immigrants testified favorably to Castro-Ayon, but the prosecution then called the interrogating agent, who testified that their trial testimony conflicted with their sworn statements during interrogation. The trial court admitted the agent's testimony both to impeach the immigrants and as substantive evidence of Castro-Ayon's guilt. Castro-Ayon was convicted and appealed.
Whether a witness's sworn statement made during a formal police interrogation qualifies as an admissible prior inconsistent statement under Federal Rule of Evidence 801(d)(1)(A) when the witness later testifies inconsistently with it at trial.