National Motor Freight Traffic Ass'n v. United States

How later courts describe this case

• stating that section 1503 proscribes “the directing of threats against witnesses or otherwise impeding the administration of justice”
• silencing of witness procured through threats of violence waives right to confront witness
• grand jury testimony admissible at trial because made under oath, never recanted, based on first-hand knowledge, and best evidence available
• in drug prosecution, silencing of witness through threats of violence waived right to confront witness
• defendant’s right to confrontation would preclude introduction of the witness’ prior statements, except for the fact that defendant himself procured the witness’ refusal to testify at trial
• “The fact that a defendant is unable to cross-examine the declar-ant is not always controlling on the confrontation issue since the right of cross-examination is not absolute.”
• "The fact that a defendant is unable to cross-examine the declarant is not always controlling on the confrontation issue since the right of cross-examination is not absolute."
• explicit finding by the district court that the grand jury witness' unwillingness to testify at trial was a product of defendant's coercion