HEADLEY V. TILGHAM
53 F.3d 472 (2nd Cir. 1995)
NATURE OF THE CASE: This was a prosecution on narcotics charges and a conspiracy and an
appeal over the use of statements from an unidentified caller.
FACTS: Headley (D) was charged with possession of narcotics with intent to distribute and
conspiracy to distribute. During trial, the statements of an unidentified Jamaican caller
were admitted into evidence as those of a co-conspirator made during and in furtherance of
the conspiracy. D was convicted and appealed. The Appeals court determined that it did not
need to struggle with the co-conspirator argument because it could affirm on the ground that
the statements were admissible nonhearsay under Oguns.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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