Ramirez
United States v. Ramirez
Opinion
Lead Opinion
MEMORANDUM *
We have jurisdiction over Defendants’ appeals pursuant to 28 U.S.C. § 1291 , and we affirm.
I
INEFFECTIVE ASSISTANCE OF COUNSEL
Ineffective assistance of counsel claims are generally addressed on collateral, not on direct, appeal. 1 In this case, neither exception to this general rule applies. 2 The court expresses no view on the merits of any ineffective assistance claims presented.
II
CONFRONTATION CLAUSE
Defendants raise a number of Confrontation Clause issues. Because none of these issues was raised before the trial court, we review them for plain error. 3 Additionally, they are subject to harmless error analysis.
*83 A. Informants’Statements
Defendants object to a number of statements made by Detective Haskins. None of the statements merits reversal. Haskins’ statements regarding the unidentified informant were not introduced for their truth, but to provide background regarding the investigation. Thus, they were admissible. 5 The introduction of Haskins’ testimony regarding the consistency of Kathy Ramirez’s statements with the statements of other informants was not clear error, given the volume of Haskins’ testimony and the passing nature of the…