U.S. v. Walker

In prosecution on drug conspiracy and firearm charges, Dist. Ct. erred in admitting audio and video recordings between defendants and non-testifying third-party, which contained inculpatory statements by third-party concerning defendants' involvement in plan to rob drug stash house and to obtain firearm to assist in said robbery. While prosecutor was properly allowed to admit portions of recordings to give context to defendants' statements contained therein, other portions could only be offered for truth of matters asserted in said recordings, and thus violated defendants' confrontational rights. However, error was harmless where defendants' own statements established their participation in plan to rob stash house and to obtain gun to do so.