United States v. Jackson
United States Court of Appeals for the Second Circuit
335 F.3d 170 (2d Cir. 2003)
Charles Jackson (defendant) and Steve Brown were charged together with conspiring to import cocaine, and Brown pleaded guilty while stating during his plea hearing that he had not supervised Jackson in the conspiracy and had not asked Jackson to smuggle any cocaine. At Jackson's own trial, he sought to introduce Brown's exculpatory statements about him, but the district court excluded them as hearsay, and the jury convicted Jackson, who appealed.
Whether a specific statement within a co-conspirator's plea allocution that exculpates the defendant, rather than inculpating the declarant, is admissible under the statement-against-interest hearsay exception simply because the broader allocution is generally self-inculpatory.