The case focused on the district court's drug-quantity finding.
The Court determined the district court committed reversible error by relying heavily upon coconspirator plea agreements to determine the drug quantities attributable to the defendants on the ground that the plea agreements were reliable statements against interest under Fed. R. Evid. 804(b)(3).
Specifically, the Court held: "At sentencing, district courts may not rely solely on Rule 804(b)(3) to use non-self-inculpatory statements in a co-conspirator’s plea agreement to determine a defendant’s drug-quantity liability."
Nor did the Court find the government's other evidence sufficiently corroborating.
Accordingly, the Court concluded: "Here, the factual bases in the plea agreements were neither inherently reliable as statements against interest nor corroborated by other information that made their reliability apparent. They were also demonstrably made the bases of the Veras’ sentences. Accordingly, we vacate the sentences and remand for resentencing."
Specifically, the Court held: "At sentencing, district courts may not rely solely on Rule 804(b)(3) to use non-self-inculpatory statements in a co-conspirator’s plea agreement to determine a defendant’s drug-quantity liability."
Nor did the Court find the government's other evidence sufficiently corroborating.
Accordingly, the Court concluded: "Here, the factual bases in the plea agreements were neither inherently reliable as statements against interest nor corroborated by other information that made their reliability apparent. They were also demonstrably made the bases of the Veras’ sentences. Accordingly, we vacate the sentences and remand for resentencing."
