United States v. Emerson Pavilus

Summary

The Third Circuit affirmed the district court's conviction of Emerson Pavilus, holding that the conditional admission of co‑conspirator statements under Fed. R. Evid. 801(d)(2)(E) was proper. The court found sufficient evidence of a conspiracy and concluded the statements were made in furtherance of that conspiracy. The lack of an explicit judicial finding of conspiracy did not render the admission reversible.