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Name: People v. Castille
Case #: A089623
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 05/24/2005

On remand from the United States Supreme Court following Crawford v. Washington (2004) 541 U.S. 36, the court once again held that statements elicited from three defendants in a joint interview were properly admitted against all three at trial. The defendants had each made admissions that the court found were clearly admissible against themselves, but each had also made statements regarding the other two defendants. The court held that these statements were properly admitted as adoptive admissions where the defendant in question had unequivocally confirmed the codefendant’s accusation or version of events, citing People v. Combs (2004) 34 Cal.4th 821, in which the California Supreme Court held that statements leading to adoptive admissions did not invoke Crawford because they were properly admitted for a non-hearsay purpose, i.e., to give meaning to the defendant’s own statement amounting to an adoptive admission. In regard to an instance in which one defendant’s response to a codefendant’s accusation was equivocal, the court held that the question of whether this constituted an adoptive admission was properly left to the jury to decide, and even assuming error, the issue was harmless beyond a reasonable doubt.