Anthony Zottola, Sr. v. United States

Whether a defendant’s right to present a defense is violated when he is precluded from offering a declarant’s out-of-court, self-inculpatory narrative that tends to demonstrate third-party culpability where the circumstances clearly indicate the statement’s trustworthiness; whether the statement offered by Petitioner was admissible under Fed. R. Evid. 804(b)(3) because it was, in context, a declaration against penal interest?

a) Does empaneling an anonymous jury violate the presumption of innocence, the right to a fair and public trial, and the right to an impartial jury, in the absence of grounds for finding that alleged obstructive conduct of the defendant related to tampering with or threatening witnesses, jurors, or other trial participants; b) in determining whether to empanel an anonymous jury in a criminal case, must the court consider alternatives to full anonymity and state its reasons for denying such relief?