United States v. Anthony Williams, 21-1280

Anthony Williams was on federal supervised release for a felon-in-possession conviction when he rear-ended another car in Grand Rapids, MI.
He had a backpack in his car containing marijuana, drug-dealing paraphernalia, and ammunition; after the collision he ran from the scene with the backpack and later returned without it.
The other driver reported the hit-and-run to 911; police tracked footprints in fresh snow to a wooded area and recovered Williams’s backpack with the contraband.
Officers arrested Williams; federal prosecutors moved to revoke his supervised release for new offenses and possession of drugs/ammunition.
At the revocation hearing officers testified and the government admitted a police report and body-camera footage containing the other driver’s statements; the driver did not testify.
Williams objected that the driver’s statements were hearsay and that he had a confrontation right; the district court overruled the objection, found violations, revoked supervised release, and Williams appealed.

Issue	Williams' Argument	Government's Argument	Held
Whether hearsay and confrontation rules bar admission of the driver’s out-of-court statements at a supervised-release revocation hearing	Admission violated hearsay rule and Williams’ right to confront adverse witnesses	Revocation proceedings are more flexible; hearsay and confrontation protections applicable to criminal trials do not apply	Court held neither hearsay ban nor Confrontation Clause bars admission in revocation proceedings; admission proper
Whether the driver’s statements met the minimal indicia of reliability required for hearsay admissibility in a revocation hearing	Statements unreliable (argues inconsistency about number of vehicles)	Statements corroborated by footprints, matching description, wet clothing, and recovered backpack—meeting low reliability threshold	Court held Williams waived a full reliability challenge and, in any event, corroboration satisfied the minimal indicia of reliability; admission proper

United States v. Trevino, 7 F.4th 414 (6th Cir. 2021) (abuse-of-discretion review for evidentiary rulings in revocation hearings)
United States v. Stephenson, 928 F.2d 728 (6th Cir. 1991) (hearsay rule relaxed in supervised-release revocation proceedings)
United States v. Kirby, 418 F.3d 621 (6th Cir. 2005) (Confrontation Clause does not guarantee same protections in revocation hearings as in criminal trials)
United States v. Waters, 158 F.3d 933 (6th Cir. 1998) (Rule 32.1(b)(2)(C) does not require hearsay declarants to appear for cross-examination)
United States v. Lewis, [citation="790 F. App'x 702"] (6th Cir. 2019) (reinforcing Waters’ holding)
United States v. Silverman, 976 F.2d 1502 (6th Cir. 1992) (hearsay admissible in revocation if it has minimal indicia of reliability)
United States v. Calvetti, 836 F.3d 654 (6th Cir. 2016) (failure to develop an argument waives the issue on appeal)
United States v. Rodriguez, [citation="797 F. App'x 933"] (6th Cir. 2019) (corroboration can clear the low reliability hurdle in revocation proceedings)
United States v. Greene, 71 F.3d 232 (6th Cir. 1995) (describing the relatively low reliability standard for hearsay in revocation hearings)