United States v. Paguio
United States Court of Appeals for the Ninth Circuit
114 F.3d 928 (9th Cir. 1997)
Gil Manuel Paguio, Jr. and Angelica Acosta (defendants) were charged with falsifying a loan application that Paguio's father had heavily assisted in completing; before becoming a fugitive and unavailable to testify, Paguio's father gave a statement admitting he was at fault and that his son "had nothing to do with it." The trial court admitted only the self-inculpatory portion of the father's statement, excluding the part exonerating Paguio, and the jury convicted both defendants; they appealed, arguing the entire statement should have been admitted as a statement against interest.
Whether a statement that inculpates the declarant while also exculpating someone else is admissible in its entirety under the statement-against-interest exception to the hearsay rule.