Jones v. United States
17 A.3d 628
| D.C. | 2011Background
- Jones was convicted in the District of Columbia Superior Court of one count of possession of PCP based on a cigarette saturated with PCP.
- A suppression motion sought to exclude the PCP-laced cigarette as improper evidence; suppression hearing was held.
- Sergeant Guice testified at suppression that he observed an object fall from Jones's hand and detected PCP odor on the scene.
- At trial, Officer Viggiani testified Guice observed Jones drop a cigarette, but he did not personally see Jones drop anything.
- The government’s closing argument misstated evidence by suggesting Guice saw Jones drop a cigarette; the trial court admitted a hearsay statement about what Guice told Viggiani.
- The appellate court reversed and remanded for a new trial, finding the hearsay was improperly admitted and not harmless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Guice’s statement | Jones argues the statement is hearsay and not within a proper exception. | United States contends the statement is admissible as a state-of-mind not offered for truth. | Hearsay error; not within state-of-mind exception; admission was improper. |
| Harmless error impact | Error impacted the outcome; record shows reliance on the hearsay. | Error was harmless; proper consideration would not have changed the result. | Not harmless; reversal required for new trial. |
Key Cases Cited
- Kotteakos v. United States, 328 U.S. 750 (1946) (harmless-error standard for erroneous hearsay)
- Odemns v. United States, 901 A.2d 770 (D.C.2006) (requires proper foundation for hearsay exceptions; improper basis leads to reversal)
- Evans-Reid v. District of Columbia, 930 A.2d 930 (D.C.2007) (state-of-mind exception limited to issue of declarant's state of mind)
- Blackson v. United States, 979 A.2d 1 (D.C.2009) (state-of-mind relevance governs admissibility)
- Mercer v. United States, 864 A.2d 110 (D.C.2004) (general rule: hearsay not admissible to prove truth)
- Goines v. United States, 905 A.2d 795 (D.C.2006) (abuse of discretion standard for evidentiary rulings)
- Patton v. United States, 633 A.2d 800 (D.C.1993) (trial court must identify proper hearsay exception and foundation)