U.S. v. Lewis

In prosecution on various drug conspiracy and firearm charges stemming from police sting calling for robbery of non-existent drug house, Dist. Ct. did not err in sustaining govt.'s hearsay objection to defendant's attempt to elicit from police officer portions of defendant's own post-arrest statement that was not brought during officer's direct testimony. Officer could properly testify as to portions of defendant's post-arrest statement when testifying on behalf of govt. since defendant's statements qualified as exception to hearsay rule as party admission under Rule 801(d)(2)(A). Defendant, though, could not elicit during cross-examination other portions of same statement since Rule 801(d)(2)(A) did not provide exception for defendant seeking to introduce his own prior out-of-court statement for truth of matters asserted in said statement. Moreover, doctrine of completeness did not otherwise require that defendant be permitted to introduce said evidence where proffered testimony did not serve to explain admitted portion of his out-of-court statement.