173195P.pdf   03/05/2019  United States  v.  Craig Sutton
   U.S. Court of Appeals Case No:  17-3195
   U.S. District Court for the Western District of Missouri - Kansas City   
   [PUBLISHED] [Kelly, Author, with Gruender and Grasz, Circuit Judges] 
   Criminal case - Criminal law. In a proceeding to revoke defendant's 
   supervised release, defendant asserted that the admission of videotaped 
   unsworn statements from the witnesses regarding the allegations of an 
   assault violated his due process rights; the correctness of the admission 
   of the hearsay evidence would be reviewed de novo rather than other the 
   abuse of discretion standard; applying the test set out in U.S. v. Bell, 
   785 F.2d 640 (8th Cir. 1086), the government failed to establish why 
   confrontation was undesirable or impractical and failed to establish the 
   reliability of the evidence the government was offering in place of live 
   testimony; reversed and remanded for further proceedings as the district 
   court deems necessary.