Fourth Circuit: USA v. Wendy Annette Moore

Crim

No variance from indictment when a court instructs according to both prongs of a statute when the indictment only charged one prong of the statute.

The trustworthiness of a statement against interest hearsay exception refers to the statement actually made, not the trustworthiness of the reporting.  No confrontation clause issue in statement to fellow detainee.

No plain error in admission of statements of prior bad acts/character, as gov't was required to correct.

http://www.ca4.uscourts.gov/Opinions/Published/144645.P.pdf