U.S. v. Jackson

In prosecution on drug charges, Dist. Ct. did not err in admitting recordings showing confidential source purchasing drugs from defendant, even though confidential source did not testify at trial. Government laid out proper foundation for recordings via officers who participated in setting up said purchases and witnessing confidential source making said purchases. Officers also established chain of custody of physical evidence arising out of said sales, and Dist. Ct. gave appropriate limiting instruction that told jury to consider statements made by confidential source not for their truth, but rather for purposes of giving context to defendant’s statements in recordings. Ct. rejected defendant’s claim that said admission violated Confrontation Clause. Ct. also rejected defendant’s claim that his life sentence on drug distribution charge should have been reduced to 25 years under First Step Act, where said Act went into effect shortly after his sentencing hearing, since said Act was not retroactive.