Williamson v. United States Case Brief

Why is the case important?

Harris was pulled over by the police for erratic driving, and a subsequent search revealed several kilos of cocaine. He gave one version of how he got the drugs during his first interview with the police, but subsequently changed his story.

Facts of the case

Question

Whether Harris’s statements to law enforcement were admissible under F.R.E Rule 804(b)(3) dealing with statements against interest?

Answer

Justice Sandra Day O’Connor (J. O’Connor) found that some of the statements were admissible and some were not. Only those statements that were directly inculpatory fell under the exception to the hearsay rule dealing with statements against interest. All other statements in the larger narrative should have been excluded.

Conclusion

The Court held that Rule 804(b)(3) does not allow admission of non-self-inculpatory statements, even if they are contained with a broader narrative that is generally self-inculpatory. Furthermore, the Court noted that in the case at hand, it could not be concluded that all of the driver’s statements had been properly admitted, as the record did not show that the District Court or the Court of Appeals had inquired whether each of the statements was truly self-inculpatory therefore, the Court ruled that the case should be remanded to the Court of Appeals to conduct this inquiry.

  • Case Brief: 1994
  • Petitioner: Williamson
  • Respondent: United States
  • Decided by: Rehnquist Court

Citation: 512 US 594 (1994)
Argued: Apr 25, 1994
Decided: Jun 27, 1994