Criminal Law and Procedure
Hawaii Supreme Court reasonably applied Chambers v. Mississippi to uphold exclusion of testimony regarding third party’s confession at defendant’s trial based on weight U.S. Supreme Court had placed upon reliability for such evidence to be admitted in Chambers; Chambers was reasonably distinguished since excluded testimony at issue in this case was materially less trustworthy than the excluded testimony in Chambers; third party was unavailable to testify; and there was doubt not only about the truthfulness of the alleged confessions but also about whether those confessions were ever made.
Christian v. Frank – filed February 19, 2010
Cite as 08-17236
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Immigration Law
Alien’s felony conviction for receipt of a stolen vehicle in violation of California Penal Code Sec. 496d(a) qualifies categorically as a conviction for an aggravated felony but does not qualify categorically as a crime involving moral turpitude.
Alvarez-Reynaga v. Holder – filed February 19, 2010
Cite as 08-70253

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