U.S. v. Javell

In prosecution on mortgage-based, wire fraud charges, Dist. Ct. did not err in admitting co-defendant's post-arrest statement, even though defendant argued that said admission violated Confrontation Clause because statement contained incriminating references to defendant. Record failed to support defendant's claim that post-arrest statement contained any facially incriminating evidence, and any possible reference to defendant in statement had been redacted prior to said admission. Fact that Dist. Ct. failed to instruct jury that it could not consider post-arrest statement as evidence against anyone other than co-defendant did not prejudice defendant in view of overwhelming nature of other evidence establishing defendant's guilt.