United States v. Duran Samaniego
United States Court of Appeals for the Eleventh Circuit
345 F.3d 1280 (11th Cir. 2003)
Boxer Roberto Duran Samaniego (defendant) claimed his championship belts were stolen by his brother-in-law, Bolivar Iglesias, and recovered when Luis Gonzalez Baez (defendant) tried to sell them to federal agents; the government filed an interpleader action to decide ownership. Duran could not locate Iglesias, a Panamanian national living abroad, despite enlisting Iglesias's family, so he sought to introduce family members' testimony that Iglesias had apologized for stealing the belts. The district court admitted this testimony under the state-of-mind hearsay exception rather than reaching the statement-against-interest theory, the jury found for Duran, and Baez appealed.
Whether a declarant must be unavailable at the time of trial for the declarant's statement against interest to be admissible as an exception to the hearsay rule.