## Facts

- The federal government ran a sting operation aimed at identifying car purchases allegedly funded with proceeds from cocaine trafficking.
- James Spriggs, a Maryland used-car dealer, was charged after the operation and later tried in the U.S. District Court for the District of Columbia on money-laundering and related counts.
- At trial, the prosecution called Rawls, a former detective, as an expert witness to give an “overview” of how local drug dealers purchased vehicles.
- On direct examination, the government asked Rawls what he knew about where local drug dealers bought their cars.
- Rawls testified that, based on interviews he had conducted, he learned that local drug dealers purchased cars at local dealerships.
- Spriggs did not object at the moment Rawls gave this testimony.
- During cross-examination, defense counsel raised concerns about the testimony at a bench conference; the district court indicated the matter could be addressed later.
- Defense counsel moved to strike the testimony the next day.
- Spriggs was convicted.
- On appeal, Spriggs argued that Rawls’s testimony was inadmissible hearsay and should not have been admitted, and he also challenged other trial rulings, including limits on defense evidence and aspects of sentencing.

## Issues

1. Whether the district court improperly admitted hearsay when Rawls testified, as an expert witness, about what unnamed interviewees told him regarding where drug dealers bought cars.
2. Whether Spriggs preserved his hearsay objection despite not objecting immediately and moving to strike the testimony the following day.
3. Whether any error in admitting Rawls’s testimony was harmless.
4. Whether the district court erred in excluding proposed testimony from Spriggs’s probation officer offered to show Spriggs’s state of mind.
5. Whether the district court’s sentencing findings (including the loss calculation and any enhancement for sophisticated laundering) were adequately supported.

## Decision

- The D.C. Circuit vacated Spriggs’s conviction and remanded for a new trial.
- The court held that Rawls’s testimony improperly conveyed hearsay—statements from interviews—through the guise of expert testimony, and Rule 703 did not permit using an expert witness as a channel for otherwise inadmissible hearsay.
- The court concluded the objection was preserved; although counsel did not object at the instant the testimony was given and moved to strike the next day, counsel raised the problem at sidebar during cross-examination and the judge indicated it would be addressed later, making plain-error review inappropriate.
- The court found the error was not harmless because the hearsay testimony directly supported the government’s theory linking Spriggs’s dealership to drug-money purchases and the government relied on it in argument.
- The court indicated that, on retrial, the district court should reconsider excluding the probation officer’s testimony to the extent it was offered for Spriggs’s state of mind, including under Rule 803(3), and should be mindful of the limits of Rule 608(b).
- Because the conviction was vacated, the court did not resolve sentencing disputes on the merits, but it advised that any future sentence should rest on clear, particularized factual findings supporting the loss amount and any guideline enhancements.

## Legal Principles

- Fed. R. Evid. 703 does not allow a party to place inadmissible hearsay before the jury by presenting it through an expert witness; an expert may rely on certain information, but the proponent cannot use the witness to repeat hearsay for its truth.
- A hearsay objection may be treated as preserved when counsel timely raises the concern and the trial court indicates it will address the matter later; preservation does not always depend on a contemporaneous objection at the exact moment testimony is first heard.
- An evidentiary error requires reversal when it likely affected the verdict; when the hearsay supplies a key link in the prosecution’s proof and is emphasized in argument, the error may not be harmless.
- Under Rule 803(3), statements reflecting a declarant’s then-existing mental state (such as intent or plan) may be admissible for that limited purpose, subject to the rule’s boundaries.
- Rule 608(b) restricts impeachment by specific instances of conduct offered to attack a witness’s character for truthfulness, but it does not automatically bar evidence offered for another permissible purpose such as state of mind.
- Sentencing determinations must be supported by specific factual findings in the record; guideline enhancements and loss calculations require an evidentiary basis tied to the defendant’s conduct.

## Conclusion

United States v. Spriggs held that the government could not use an expert witness to convey interview-based hearsay that directly advanced the prosecution’s case, and because the testimony was preserved by defense counsel’s bench objection and was not harmless, the D.C. Circuit vacated the conviction and remanded for a new trial, while also flagging evidentiary and sentencing issues to be handled carefully on remand.


United States v. Spriggs, 102 F.3d 1245 (1996)