United States v. Lawrence Escamilla

Appellant Lawrence Escamilla was indicted in December of 1989 on'charges of conspiracy to distribute and import cocaine. Prior to the beginning of his trial, he entered into a plea agreement with the government that, in part, required him to confess fully to his role in the conspiracy, cooperate with law enforcement officers, and successfully complete a polygraph examination. After ten weeks had elapsed, and after Escamilla confessed, he took and failed a polygraph test. The government then revoked the plea agreement and took Escamilla to trial, where he was convicted largely on the basis of the statements he had made to law enforcement officers under the auspices of the plea. On appeal, Escamilla contends that the trial judge erred by admitting both his confession and some hearsay statements of a government witness and that he was denied effective assistance of counsel. Because we find that Escamilla’s confession was improperly admitted at trial, we reverse Escamilla’s conviction. Because we reverse on the grounds that his confession was inadmissible, we need not reach Escamilla’s other contentions on appeal.

BACKGROUND

Lawrence Escamillá was indicted on December 14, 1989,…