Williamson v. United States
512 U.S. 594, 114 S.Ct. 2431, 129 L.Ed.2d 476 (1994)

  • A search of Harris’ car turned up 19 kgs of cocaine. He was arrested.
  • Harris told a DEA agent that the cocaine belonged to Williamson.
    • Harris told two contradictory stories about the cocaine, though both involved Williamson.
    • Harris refused to sign a written statement or testify at trial because he claimed he was afraid of Williamson.
  • Williamson was arrested and charged with drug trafficking.
  • At trial, the prosecution attempted to introduce Harris’ statements into evidence.  Williamson objected.
    • Williamson argued that Harris’ statements were hearsay.
    • The prosecution argued that they were admissible as statements against interest by a now unavailable witness under the FRE 804(b)(3) exception.
  • The Trial Judge admitted Harris’ statement.
  • The Trial Court convicted Williamson of drug trafficking.  He appealed.
  • The Appellate Court affirmed.  Williamson appealed.
  • The US Supreme Court reversed.
    • The US Supreme Court found that in order for a statement to be admissible under FRE 804(b)(3) the statement must be clearly against the declarant’s penal interest and that a reasonable person in the declarant’s position would not have made the statement unless believing it to be true.
    • Harris admitted to possessing the drugs.  Claiming that they belonged to Williamson was not self-incriminating, in fact it was exculpatory.  Therefore, the statement was not against Harris’ interest and is not covered by the FRE 804(b)(3) exception.
      • Harris’ statements “provided only marginal evidence of his guilt.  They project an image of a person action not against his penal interest, but striving mightily to shift principle responsibility to someone else.”