10-2740 U.S. v. Yarrington

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Evidence
Rule of completeness

Confusing testimony is an insufficient basis to admit otherwise inadmissible evidence under the rule of completeness, but the error was harmless.

“The reading of the portions of the report does not seem to fit within the rule of completeness. The jury had already heard that Summerlin stated during his September 8 interview with Agent Rollins that he purchased cocaine from both Wallace and Yarrington. Agent Rollins had testified that in that interview, Summerlin said that during the early part of his relationship with Wallace, he purchased cocaine only from Wallace, but in the later part of the relationship, he purchased from Wallace and Yarrington. Although Summerlin’s testimony may have been confusing with respect to the time periods in which he purchased cocaine from Wallace and Yarrington, the reading of portions of the report was unnecessary to provide the jury with a complete view of Summerlin’s statements in the September 8 interview. The reading of portions of the report likely served the purpose of rehabilitating Summerlin.”

Affirmed.

10-2740 U.S. v. Yarrington

Appeal from the United States District Court for the Central District of Illinois, Scott, J., Tinder, J.

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