United States v. Yarrington
2011 U.S. App. LEXIS 9247
| 7th Cir. | 2011Background
- May 22, 2008, surveillance on an apartment in Springfield; Wallace drug-dealing connected to the apartment; a person named Thomas involved.
- Wallace was arrested after a traffic stop and suspected cocaine residue found; later, Yarrington’s Chevy Avalanche was stopped and he consented to searches of vehicle and apartment.
- Yarrington admitted he did not live at the apartment but consent was eventually obtained from his girlfriend Melody Pryor to search.
- The music room in the apartment contained cocaine, cutting agents, packaging materials, and a large cash amount; fingerprints linked to Yarrington were found on cocaine bags.
- Yarrington was interviewed at the jail; he admitted handling and distributing cocaine for Wallace, and the government moved to introduce a report of another interview; Summerlin’s testimony and phone records connected Wallace, Summerlin, and Yarrington.
- A jury convicted Yarrington of possession with intent to distribute cocaine; he challenged (1) Batson peremptory strike of an African American juror, and (2) admission/readings from a September 8 interview report under the completeness doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge to peremptory strike | District court failed to conduct meaningful Batson inquiry; strike was pretextual. | Government provided race-neutral explanations; district court properly weighed credibility. | No clear error; government's reasons credible; Batson claim fails. |
| Readings from Summerlin interview report | Reading the report violated completeness and prejudiced the defense. | Reading was necessary to place statements in context and was harmless. | Harmless error; evidence supported guilt independent of the readings. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (1986) (racial discrimination in jury selection prohibited; three-step test)
- United States v. Taylor, 636 F.3d 901 (7th Cir. 2011) (framework for Batson review; deference to credibility findings)
- United States v. White, 582 F.3d 787 (7th Cir. 2009) (pretext inquiry; race-neutral explanations must be credible)
- United States v. McMath, 559 F.3d 657 (7th Cir. 2009) (pretext and credibility in Batson analysis)
- United States v. Sandoval, 241 F.3d 549 (7th Cir. 2001) (race-neutral reasons for striking juror based on knowledge of witnesses)
- United States v. Vasquez, 635 F.3d 889 (7th Cir. 2011) (harmless-error standard for evidentiary missteps)