Professional Documents
Culture Documents
Unpublished
Unpublished
No. 15-4497
Appeal from the United States District Court for the Eastern
District of Virginia, at Richmond.
Henry E. Hudson, District
Judge. (3:14-cr-00139-HEH-1)
Submitted:
Decided:
PER CURIAM:
A jury convicted Eddie Blanchard of conspiracy to commit
mail and wire fraud, in violation of 18 U.S.C. 1349 (2012),
wire fraud, in violation of 18 U.S.C. 1343, 2 (2012), mail
fraud, in violation of 18 U.S.C. 1341, 2 (2012), aggravated
identity
theft,
(2012),
conspiracy
violation
of
in
18
violation
to
U.S.C.
of
18
obstruct
1512(k)
U.S.C.
official
(2012),
1028A(a)(1),
proceedings,
and
obstruction
2
in
of
whether
the
codefendant
Junior
Jean
describing
the
district
court
Merilias
conspiracy
the
and
erred
out-of-court
implicating
testimony
in
statements,
Blanchard
in
Merilias
the
conspiracy,
through
girlfriend.
of
admitting
former
courts judgment.
The
district
court
admitted
Merilias
statements
to
his
We review the
district
for
courts
discretion.
admission
of
these
statements
abuse
of
Cir.
2013).
declarant
For
must
inculpatory,
corroborated.
the
be
and
Id.
statements
unavailable,
(3)
the
to
be
(2)
the
statement
admissible,
(1)
the
statement
must
be
must
be
sufficiently
conclude
that
the
district
court
did
not
abuse
its
At the time he
made the statements, Merilia was aware that law enforcement was
investigating codefendant Ramoth Jean, and later himself.
While
Blanchard
were
lifelong
friends.
Moreover, Merilia
Finally,
Merilias
accordance
with
Anders,
we
have
reviewed
the
entire
We
therefore
affirm
the
district
courts
judgment.
but
counsel
that
such
petition
would
be
are
adequately
presented
in
the
materials
before
this court and argument would not aid the decisional process.
AFFIRMED