United States v. Sonja Harrison

Sonja Harrison appeals her conviction for money laundering in violation of 18 U.S.C. § 1956(a)(1)(B). She argues that the district court erred in admitting a statement she gave to federal agents at the time of her arrest and in instructing the jury regarding the coconspirator exception to the hearsay rule. We have jurisdiction, 28 U.S.C. § 1291 , and we reverse.

I

In 1990, Harrison purchased two properties with funds provided by Pierre Clifton Marshall, her companion and the father of her children. She lived in the first, a house in Canoga Park, California, and managed the second, an apartment complex in Inglewood, California. To make the down payment for the home, Harrison used four cashier’s checks. Each of the checks was for less than $10,000, the amount triggering federal reporting requirements. 31 C.F.R. § 103 .-22(a)(1). To make the down payment for the apartment complex, Harrison used $55,000 in cash, which Marshall had provided. The escrow documents for both properties reflected purchase prices that were less than the actual amounts Harrison and Marshall paid.

The government contends that Harrison used proceeds from Marshall’s drug trafficking to pay for the properties.…