Bridges v. Clark, 59 A.3d 978 (2013)

Citation: Bridges v. Clark, 59 A.3d 978 (2013)
Parent Document: Bridges v. Clark, 59 A.3d 978 (2013)
Jurisdiction: DC (municipal)
Effective Date: 2013-01-24
Original Source: https://www.courtlistener.com/opinion/5146099/bridges-v-clark/ ↗

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For these reasons, we conclude that Mr. Clark manifested his adoption and belief in the truth of the pertinent part of the Love affidavit. This conclusion finds substantial support in prior decisions of this court and the United States Court of Appeals for the District of Columbia Circuit. See Harris, 834 A.2d at 115-23 (trial court erred by completely excluding *987police officer’s affidavit, which was signed by prosecutor and submitted as part of search-warrant application, because at a minimum one portion of affidavit should have been admitted as adoptive admission); United States v. Warren, 310 U.S.App.D.C. 1, 9-10, 42 F.3d 647, 656-56 (1994) (trial court erred by excluding sworn statement by police officer, which was attached to criminal complaint submitted to court, because statement should have been admitted as adoptive admission); United States v. Morgan, 189 U.S.App.D.C. 155, 159-61, 581 F.2d 933, 937-39 (1978) (trial court erred by excluding police officer’s affidavit, which was used to support search-warrant request, because statement should have been admitted as adoptive admission; “where, as here, the government has indicated in a sworn affidavit to a judicial officer that it believes particular statements are trustworthy, it may not sustain an objection to the subsequent introduction of those statements on grounds that they are hearsay”).6

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