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United States v. Vella

United States Court of Appeals, Third Circuit
Sep 19, 1977
562 F.2d 275 (3d Cir. 1977)

Summary

holding that “the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the [defendant] under the rule of Brady . . . or the Jencks Act”

Summary of this case from United States v. Woznichak

Opinion

No. 77-1201.

Submitted under Third Circuit Rule 12(6) September 8, 1977.

Decided September 19, 1977.

Leonard G. Ambrose, III, Erie, Pa., for appellant.

Blair A. Griffith, U.S. Atty., Henry G. Barr, Asst. U.S. Atty., James J. West, Asst. U.S. Atty. Pittsburgh, Pa., for appellee.

Appeal from the United States District Court for the Western District of Pennsylvania.

Before ALDISERT, ROSENN and GARTH, Circuit Judges.


OPINION OF THE COURT


In this appeal from his conviction of conspiracy and operating an illegal gambling business in violation of federal law, 18 U.S.C. §§ 371, 1955, appellant Peter Vella contends that the district court erred in refusing to exclude the testimony of two F.B.I. agents who had destroyed the rough notes of interviews they held with Vella. Appellant claims that the written notes constituted statements producible under the Jencks Act, 18 U.S.C. § 3500, and that their destruction (a) deprived him of a full and fair opportunity to cross-examine the agents, and (b) violated the principles of Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963).

A similar contention was made before this court in United States v. Harris, 560 F.2d 148 (3d Cir., 1977), in which this court stated:

At argument of this case, counsel for the Government stated to the court that it is now the policy of the Federal Bureau of Investigation to preserve rough notes of interviews. We accept this representation and, accordingly, do not meet the issue insofar as it affects future conduct of F.B.I. agents. See United States v. Harrison, 173 U.S.App.D.C. 260, 524 F.2d 421 (1975).

560 F.2d at 149.

In the present appeal, however, the government intimates that the preservation of rough interview notes is not so much a new "policy" as it is a temporary stopgap. We reject this approach. To avoid future misunderstandings, we specifically adopt the precepts announced in United States v. Harrison, 173 U.S.App.D.C. 260, 524 F.2d 421 (1975), as the law in this circuit, to-wit, the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the appellant under the rule of Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), or the Jencks Act.

In its brief, the government states:

We would point out that based on the fact that the Ninth Circuit has adopted the Harrison case, the FBI is now attempting to set up procedures where rough interview notes will be preserved in the future. We do not urge this Court to rely on mootness as a basis for deciding this case because we believe this added burden on law enforcement is unnecessary and should eventually be declared such in order that resources soon to be dedicated to the preservation of rough notes can be better used.

Government Brief at 12 n.7.

For the purposes of the present appeal, we have determined that in light of the other evidence in the record, as well as the apparent good faith administrative decision which led to the destruction of the notes, the error must be considered harmless.

Having considered this and appellant's other contention, to-wit, that the district court's findings after an in camera inspection of the grand jury testimony of Alfred Pilliteri and Patsy Morabito, as expressed in its January 10, 1977, memorandum order, were clearly erroneous, we conclude that the district court's judgment should stand.

The judgment of the district court will be affirmed.


Summaries of

United States v. Vella

United States Court of Appeals, Third Circuit
Sep 19, 1977
562 F.2d 275 (3d Cir. 1977)

holding that “the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the [defendant] under the rule of Brady . . . or the Jencks Act”

Summary of this case from United States v. Woznichak

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977) (per curiam), we held that "the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the [defendant] under the rule of Brady... or the Jencks Act."

Summary of this case from U.S. v. Ramos

In Vella and Ammar, we explained the requirement for retaining rough notes of interviews in such unambiguous terms that it would be futile to try to elucidate further here, for what we meant cannot be stated more clearly.

Summary of this case from U.S. v. Ramos

In Vella, we relied on United States v. Harrison, 524 F.2d 421 (D.C.Cir. 1975), in requiring preservation of rough notes.

Summary of this case from U.S. v. Ramos

In Vella, without elaboration, we stated that "in light of the other evidence in the record, as well as the apparent good faith administrative decision which led to the destruction of the notes, the error must be considered harmless."

Summary of this case from U.S. v. Ramos

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977) (per curiam), we held with regard to the first category that "the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the [defendant] under the rule in Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963) [requiring disclosure of exculpatory evidence] or the Jencks Act."

Summary of this case from United States v. Ammar

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Edwards

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Harris

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Fenstermaker

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Collier

In United States v. Vella, 562 F.2d 275 (1977) the Court of Appeals held that “rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in” Brady, 373 U.S. 83 or the Jencks Act.

Summary of this case from United States v. Baldwin

In United States v. Vella, 562 F.2d 275 (1977) the Court of Appeals held that “rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), or the Jencks Act.” Id.

Summary of this case from United States v. Brown

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977) (per curiam), we held that "the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to the [defendant] under the rule of Brady... or the Jencks Act."

Summary of this case from United States v. Rinaldi

In Vella and Ammar, we explained the requirement for retaining rough notes of interviews in such unambiguous terms that it would be futile to try to elucidate further here, for what we meant cannot be stated more clearly.

Summary of this case from United States v. Rinaldi

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Johnson

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Beech

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Hawkins

In United States v. Vella, 562 F.2d 275 (3d Cir. 1977), the Third Circuit held that "rough interview notes of [law enforcement officers] should be kept and produced so that the trial court can determine whether the notes should be made available to the defendant under the rule in Brady... or the Jencks Act."

Summary of this case from United States v. Tarnai

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.

Summary of this case from United States v. Donis

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.

Summary of this case from U.S. v. Trover

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.

Summary of this case from U.S. v. Thomas

In Vella, 562 F.2d at 275-76, the Third Circuit adopted the approach of the D.C. Circuit Court of Appeals as to preservation of rough notes, holding that "the rough interview notes of F.B.I. agents should be kept and produced so that the trial court can determine whether the notes should be made available to [a defendant] under Brady v. Maryland, 373 U.S. 83 (1963) or the Jencks Act."

Summary of this case from U.S. v. Rucci

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.

Summary of this case from U.S. v. Goggins

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.See also United States v. Ammar, 714 F.2d 238, 259 (3d Cir. 1983) (extending rule to require preservation of drafts of agents' reports).

Summary of this case from U.S. v. Morris

In United States v. Vella, 562 F.2d 275, 276 (3d Cir. 1977), the Third Circuit held that rough interview notes should be preserved so that the court can determine whether they should be made available to the defendant under Brady or the Jencks Act.

Summary of this case from U.S. v. Lightfoot
Case details for

United States v. Vella

Case Details

Full title:UNITED STATES OF AMERICA v. PETER VELLA, APPELLANT

Court:United States Court of Appeals, Third Circuit

Date published: Sep 19, 1977

Citations

562 F.2d 275 (3d Cir. 1977)

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