Muniz-Herrera v. United States

How later courts describe this case

• holding that victim’s hearsay statements indicating that she intended to end the marriage reflected her state of mind and were admissible under Rule 803(3)
• distinguishing substance from form of discovery and reasoning that for purposes of our discovery statutes, a defendant must simply be provided with the substance or essence of a witness’s oral statement
• there is no absolute affirmative duty to investigate juror misconduct absent a report of prejudicial conduct
• twenty-two years not too remote