Supreme Court Report

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Sam Sando v. United States

IFP petition · United States Court of Appeals for the Eighth Circuit, No. 25-1065 · judgment May 19, 2026


Certiorari denied · October 13, 2026

Question presented

Whether the district court properly (1) excluded the admission of sworn deposition statements used to impeach a hearsay declarant, (2) excluded a witness’s prior sworn testimony under Rule 801 when the testimony contained a statement against interest made by another declarant, (3) excluded evidence offered to impeach a government witness because the statement was made during an investigative interview, and (4) admitted evidence of an unrelated domestic incident under Rule 404(b) when the Government failed to identify a permissible non-propensity purpose for the evidence.

Counsel of record

For petitioner
Alexander David Smith
Parrish Law Firm

For respondent
D. John Sauer
Solicitor General

Case

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, October 13, 2026 · Certiorari denied

Proceedings

  1. Oct 13 2026
    Petition DENIED.
  2. Sep 24 2026
    DISTRIBUTED for Conference of 10/9/2026.
  3. Sep 22 2026
    Waiver of right of respondent United States to respond filed.
  4. Sep 11 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due October 15, 2026)