United States v. Hawkins, No. 14-2210 (7th Cir. 2015)
Annotate this CaseTwo men robbed a Chicago bank. When Warfield was arrested on the day of the robbery, he told the FBI that he had robbed the bank with Hawkins. Hawkins and Warfield were indicted. During Warfield’s proffer session with the government, Warfield recanted his initial statement and, instead of Hawkins, claimed that he had robbed the bank with Brooks, also called “Stank.” (Earlier, Warfield also told a confidential informant in prison that a masked bank robber depicted on television was his “co-defendant” who was called “Stank.”) Warfield pleaded guilty, but refused to identify the other robber during his plea colloquy. Before trial, Hawkins moved to admit Warfield’s proffer statement regarding Brooks’s supposed involvement. Because Warfield intended to assert his Fifth Amendment privilege not to testify, Hawkins argued that the statement was admissible under Federal Rule of Evidence 804(b)(3) as a statement against penal interest made by an unavailable witness. The court denied Hawkins’s motion, excluding Warfield’s statement on grounds that it was not supported by corroborating circumstances that clearly indicated its trustworthiness. Hawkins was convicted of bank robbery and sentenced to 100 months’ imprisonment. The Seventh Circuit affirmed; viewed as a whole, the circumstances do not “clearly suggest” that Warfield’s statement was trustworthy.
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