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United States v. Duran Samaniego - 345 F.3d 1280 (11th Cir. 2003)


District courts have discretion to decide if there is a pattern of delay or a deliberate refusal to comply with court orders or directions that justifies a sanction.


Roberto Duran, a boxer claimed that his championship belts were stolen from his house in Panama by his brother-in-law, Bolivar Iglesias. Eventually, it was found out that Duran’s championship belts came into the hands of Luis Gonzalez Baez, a Miami businessman. Baez attempted to sell the belts to undercover FBI agents (who had set up a sting operation) for $ 200,000. Baez was arrested, but he claimed that the belts had not been stolen. The government confiscated the belts and filed an interpleader action in federal district court to determine whether Duran or Baez is the rightful owner of the belts. At trial, the district court permitted, over Baez’s objections, a number of witnesses, including Duran and some of his family members. These witnesses testified that Iglesias apologized in their presence for stealing the belts. The district court returned a verdict in favor of Duran. Thereafter, Baez challenged the decision of the district court and alleged that the court should not have admitted testimony about a purported apology from Bolivar Iglesias. According to Baez, the testimony in question is inadmissible hearsay. On the other hand, the district posited that the out-of-court statement described an existing state of mind or emotion, and for that reason fit within the hearsay exception set out in Federal Rule of Evidence 803(3).


Was the testimony about a purported apology from Bolivar Iglesias an inadmissible hearsay?




The Court held that the apology was a statement against interest because it subjected the declarant, Bolivar Iglesias, to civil or criminal liability. Although the district court admitted the statement on the wrong ground, under Fed. R. Evid. 803(3), the Court held that the district court did not abuse its discretion in admitting the statement. According to the Court, the apology was admissible under Fed. R. Evid. 804(b)(3). 

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