United States v. Arteaga

United States Court of Appeals for the Ninth Circuit · 1997 · Evidence

117 F.3d 388 (9th Cir. 1997)

Updated August 22, 2026

EvidenceHearsaySufficiency of the evidencelimiting instructionRule 105business recordsRule 803(6)catch-all exception

Facts

The prosecution relied heavily on Western Union records, including "to-send-money" and "to-receive-money" forms, to prove money transfers connected to a drug-money laundering scheme. The district court ultimately instructed the jury that customer-provided information on the Western Union forms could not be considered for the truth of the matters asserted. Two "to-send-money" forms were found in Arteaga's apartment on the day of one charged transfer, and they used names independently shown to be aliases connected to the conspiracy. As to Arrango-Laverde, one "to-receive-money" form contained her driver's license number as recorded by the receiving clerk, but other counts relied only on internal records and endorsed checks using the alias "Linda Arce" without independent proof linking those signatures to her.

Issue

When customer-provided statements on business records are admitted with a limiting instruction barring truth use, may the jury nevertheless rely on them for non-hearsay purposes, and was the remaining evidence sufficient to support these money laundering convictions? More specifically, did the evidence, viewed consistently with the limiting instruction, sufficiently connect Arteaga and Arrango-Laverde to the charged Western Union transactions?

Rule

On appellate review, the sufficiency of the evidence must be assessed in light of the trial court's limiting instruction, because jurors are presumed to follow it. An out-of-court statement not admitted for its truth may still be considered for legitimate non-hearsay purposes, including as circumstantial evidence of state of mind or knowledge. But customer-provided information that is not linked to the defendant cannot alone establish that defendant's participation, while non-customer information recorded by a clerk may be considered for its truth if it falls outside the limiting instruction.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal prosecution in Seattle for laundering cash through a wire service, the trial judge admitted sender forms but instructed the jury that customer-written portions could not be considered for their truth. The government did not object and instead told the court it was not offering those entries for their truth. On appeal after conviction, the government argues the entries should be treated as true because they qualified as party admissions.

How should the appellate court evaluate the sufficiency of the evidence?

Explanation. The governing rule is that appellate sufficiency review must honor the trial court’s limiting instruction because jurors are presumed to follow it. Once the jury was told not to consider customer-provided statements for their truth, the government cannot undo that choice on appeal by invoking other theories of admissibility.