United States v. Ocasio-Ruiz, 779 F.3d 43

Ocasio-Ruiz was convicted in Puerto Rico for carjacking and murder based primarily on testimony of a cooperating witness who placed him in the back seat and heard one gunshot after Ocasio-Ruiz asked Maldonado-Castro for a pistol.
Maldonado-Castro (an alleged co-conspirator) was killed before trial. Ocasio-Ruiz sought to admit Maldonado-Castro’s out-of-court confession as testified to by Maldonado-Castro’s mother: she said her son confessed he "acted alone" and "was by himself all the time."
The district court found Maldonado-Castro unavailable and the statement against interest, but excluded the mother’s testimony under Fed. R. Evid. 804(b)(3) for lack of corroborating circumstances, concluding there were "absolutely no corroborating circumstances."
The jury convicted Ocasio-Ruiz on four counts; he received consecutive life sentences on several counts and ten years on another.
On appeal the First Circuit held the district court erred as a matter of law by finding no corroboration, reversed and vacated the convictions, and remanded; it also held the conspiracy count’s sentence was improperly life and should be capped by the general conspiracy statute’s five-year maximum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility under Fed. R. Evid. 804(b)(3)	Ocasio-Ruiz: mother’s testimony is a statement against interest by an unavailable declarant and is corroborated by familial context, detail, noncustodial setting	Government: insufficient corroboration; district court found none and excluded testimony	Reversed: family relationship and other facts supply at least some corroboration; district court erred by finding "absolutely no corroborating circumstances" without proper analysis
Harmless-error inquiry	Ocasio-Ruiz: exclusion was not harmless because admission could have led jury to credit confession over cooperating witness	Government: (did not press harmlessness on appeal)	Reversed: not highly probable the error did not affect verdict; admission could have altered jury credibility finding, so error was not harmless
Sentencing for count charging conspiracy	Ocasio-Ruiz: count one charged conspiracy under general § 371, so max sentence is five years, not life under substantive carjacking statute	Government: relied on indictment language referencing substantive statute	Held: Agrees with Ocasio-Ruiz; indictment’s narrative shows general conspiracy was charged, so five-year statutory maximum applies

Williamson v. United States, 512 U.S. 594 (Rule 804(b)(3) rationale: people normally do not make self-inculpatory statements unless true)
United States v. Barrett, 539 F.2d 244 (history and purpose of corroboration requirement for statements against interest)
United States v. Barone, 114 F.3d 1284 (familial communication can corroborate statement against interest)
United States v. Monserrate-Valentin, 729 F.3d 31 (statement to close relative may suffice as corroboration)
United States v. Pelletier, 666 F.3d 1 (nonfamilial acquaintances can sometimes supply corroboration)
United States v. Mackey, 117 F.3d 24 (corroboration standard is more than minimal; district court discretion)
United States v. Delgado-Marrero, 744 F.3d 167 (harmless-error burden on government for preserved evidentiary errors)
United States v. Vigneau, 187 F.3d 82 (definition of "highly probable" in harmless-error analysis)
United States v. Sepúlveda, 15 F.3d 1161 (factors relevant to harmless-error determination)