Background
Daniel Heggins appealed a district court judgment revoking his supervised release and sentencing him to twelve months of imprisonment. Heggins had been convicted of aiding and abetting wire fraud while on supervised release. At the revocation hearing, the district court allowed a law enforcement agent to testify about out-of-court statements made by a witness at Heggins’s wire fraud trial and to recount the substance of that witness’s prior sworn testimony. Heggins argued on appeal that the district court abused its discretion by admitting this hearsay evidence.
The court’s reasoning
The court reviewed the district court’s evidentiary decisions for abuse of discretion. While defendants are generally entitled to question adverse witnesses, the government may introduce statements from absent witnesses if it shows good cause for their unavailability. The court must balance the government’s explanation against the releasee’s interest in confrontation. Even if the admission of hearsay was erroneous, the court applies a harmless error standard. The court found that the district court’s decision was independently supported by properly admitted evidence, specifically the criminal judgment reflecting Heggins’s conviction. This judgment alone was sufficient to establish the violation by a preponderance of the evidence. Corroborating documentary evidence also linked Heggins to the conduct. Because the district court would have reached the same result without the hearsay, any error did not have a substantial or injurious effect on the outcome.
We review a district court’s evidentiary decisions in a supervised release revocation hearing for abuse of discretion.
United States v. Williams, 134 F.4th 134, 138 (4th Cir. 2025)
What it means going forward
This decision reinforces that errors in admitting hearsay evidence during supervised release revocation hearings will not automatically result in reversal if the remaining properly admitted evidence independently supports the finding of a violation.
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