Federal 7th Circuit Court
Criminal Court
Conspiracy
In prosecution on drug conspiracy charge, Dist. Ct. did not err in admitting out-of-court statement made by alleged third-party co-conspirator under co-conspirator exception to hearsay rule where disputed statement concerned conduct between third-party and another individual that did not implicate defendant in conspiracy. Alternatively, record contained sufficient evidence to establish existence of conspiracy to support admission of instant out-of-court statement, where record showed that defendant served as middleman between third-party drug seller and another individual who purchased drugs, and where third party paid cash to defendant to compensate him for his efforts at facilitating said sale.