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Name: U.S. v. Edwards
Case #: 99-30143
Court: US Court of Appeals
District 9 Cir
Opinion Date: 12/27/2000
Subsequent History: Substituted opn. filed on 12/27/00

Where the police failed to conduct a thorough initial search of the bag in which the cocaine had been found, failed to inventory numerous papers that belonged to appellant that were seized from the car he was driving, and removed the bag from the courtroom during the first trial and in violation of court rule, at which point the Tacoma bail receipt bearing appellant’s name was initially found (and which became the only evidence tying appellant to the bag), the bail receipt was inherently unreliable evidence and should have been excluded at appellant’s second trial. The only other evidence tendered as tying appellant to the bag was the testimony of Ms. Grimes, which, standing alone, the Court of Appeals found to be insufficient to support the conviction beyond a reasonable doubt. Ms. Grimes could not identify the bag she saw appellant carrying when he left her house, other than to describe it as a “dark colored bag.” Furthermore, she admitted it was dark and that she and appellant owned three different sets of luggage. The receipt did more that “corroborate” Ms. Grimes’ testimony. It provided a degree of certainty regarding ownership of the bag that Ms. Grimes’ testimony could not supply. The admission of the receipt more likely than not affected the outcome of the trial, and its admission was therefore not harmless.