FOCUS COLUMN
By Greg May
In U.S. v. Larson, 495 F.3d 1094 (9th Cir. 2007), an en banc 9th U.S. Circuit Court of Appeals resolved an apparent three-way intra-circuit split on the standard of review for Confrontation Clause challenges that are based on limitations placed on cross-examination. The 15-judge panel unanimously settled the issue - a unique point of agreement in a decision that split 4-7-4 on the merits.
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