United States v. Doerr

Doerr (defendant), who ran prostitution-related businesses and used shell companies to hide the income from taxation, was convicted of conspiracy offenses. The prosecution introduced two statements by co-conspirators under the Federal Rules of Evidence 801(d)(2)(E) exception: one a club regular's comment to the club owner about a past event, the other idle conversation between the defendant and his brother.

Whether the two statements made by other participants in the conspiracy are admissible under FRE 801(d)(2)(E).