Carl Rose v. United States

This case involves an important issue in which there is a split of authority in the lower courts regarding whether there is a reasonable expectation of privacy in the hotel room of a non-registered guest. This case implicates precisely this issue. The questions presented are: Whether the Due Process Clause and Federal Rule of Criminal Procedure 32.1(b)(2)(C) require a district court, before admitting hearsay at a supervised-release revocation hearing, to conduct an on-the-record balancing of the releasee’s confrontation interest against the government’s good cause for denying confrontation, with the reliability of the proffered hearsay as a principal factor but not the only factor. Whether a district court may admit uncorroborated hearsay from an absent complainant at a revocation hearing based solely on a finding of government good faith or witness unavailability, without specific good cause and without articulating why the releasee’s confrontation interest yields under Rule 32.1(b)(2)(C).