P. v. Hawkins CA3
In this appeal, we address an exception to a criminal defendant’s right to confront witnesses, the doctrine of forfeiture by wrongdoing. Defendant Kenneth Lequiez Hawkins was Sarah Doe’s pimp. He was arrested shortly after an incident in which he beat her and forced her to go into a vehicle and perform oral sex on a man. Doe gave two statements to the Sacramento police inculpating defendant. When she failed to appear, the trial court, over defendant’s objection, granted the prosecution’s motion to admit her two statements to a police officer and a detective, finding the forfeiture by wrongdoing exception applied because defendant had facilitated Doe’s failure to appear.
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