United States v. Pranzetti

CourtCourt of Appeals for the Ninth Circuit
DecidedFebruary 7, 2025
Docket23-3521
StatusUnpublished

This text of United States v. Pranzetti (United States v. Pranzetti) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Pranzetti, (9th Cir. 2025).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS FEB 7 2025 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 23-3521 D.C. No. Plaintiff - Appellee, 3:10-CR-00354-IM-1 District of Oregon v.

ANTHONY MICHAEL PRANZETTI, MEMORANDUM* Defendant - Appellant.

Appeal from the United States District Court for the District of Oregon Karin J. Immergut, District Judge, Presiding

Submitted February 5, 2025** Portland, Oregon

Before: BEA, KOH, and SUNG, Circuit Judges.

Anthony Michael Pranzetti appeals the judgment of the district court

revoking his supervised release and sentencing him to fourteen months in custody.

The district court did so after finding that Pranzetti committed two Grade C

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). violations1 while on supervised release. We have jurisdiction pursuant to 18 U.S.C.

§ 3742(a) and 28 U.S.C. §§ 1291 and 1294, and we affirm.

1. Pranzetti first argues that the district court violated his due process right to

confrontation at the revocation hearing. Whether a defendant has received adequate

due process at a supervised-release revocation hearing is a mixed question of law

and fact that we review de novo. See United States v. Perez, 526 F.3d 543, 547 (9th

Cir. 2008). “Less process is due” at revocation hearings, and “that process must be

flexible enough” to balance the releasee’s “right to confrontation against the

Government’s good cause for denying it.” United States v. Simmons, 812 F.2d 561,

564 (9th Cir. 1987). If we find a due process violation, we must assess whether the

violation was harmless beyond a reasonable doubt. See United States v. Comito,

177 F.3d 1166, 1170 (9th Cir. 1999).

First, the district court did not violate Pranzetti’s Fifth Amendment due

process right to confrontation when it allowed two police officers to testify by

video and allowed the Government to offer hearsay evidence. Officers Garrett

Walecki (“Walecki”) and Brandon Matz (“Matz”) (collectively, the “Officers”)

testified under oath and were cross-examined via video conference. The Officers

lived over 2,000 miles away from the location of the supervised-release revocation

1 Pranzetti’s two Grade C violations were (1) disorderly conduct and (2) unlawful possession of a controlled substance, in this case marijuana.

2 hearing, and in-person testimony would have required significant time and travel

expense and strained the staffing resources of their home police department. See

Gagnon v. Scarpelli, 411 U.S. 778, 782 n.5 (1973) (holding that “the difficulty and

expense of procuring witnesses from perhaps thousands of miles away” may justify

an “alternative to live testimony”). Pranzetti provides no support for his assertion

that his right to confrontation was compromised by the remote testimonies.

Second, the district court did not violate Pranzetti’s right to confrontation

when it allowed the Government to submit hearsay evidence. This evidence

included the affidavit of the witness who accused Pranzetti of sexually assaulting

her on the Greyhound bus (“LB”), LB’s contemporaneous text messages, LB and

another witness’s (“AK”) written statements, and body-camera footage of AK’s

interview.

Here, the hearsay evidence was reliable. See Comito, 177 F.3d at 1171

(“[T]he more subject to question the accuracy and reliability of the proffered

evidence, the greater the releasee’s interest in testing it by exercising his right to

confrontation.”). It was internally consistent, see United States v. Hall, 419 F.3d

980, 988 (9th Cir. 2005) (holding that a victim’s testimony could be admitted

despite her failure to appear at the revocation hearing because it was consistent

with the victim’s statements to others), and consistent with the Officers’

perceptions of the witnesses during the on-scene interviews. See id. at 987–88

3 (concluding that hearsay evidence was more reliable where victim’s physical

response was consistent with her hearsay statement describing the disputed

occurrence).2

For its part, the Government offered good cause for not producing AK and

LB at the revocation hearing and provided adequate substitutes for their live

testimony. See United States v. Martin, 984 F.2d 308, 313 (9th Cir. 1993)

(providing conventional “substitutes for live testimony identified by the Supreme

Court, including affidavits, depositions, and documentary evidence,” weighs in

favor of good cause (internal quotation marks and citation omitted)). LB lived out

of state, see id. (holding that difficulty and expense of procuring a witness

constitutes good cause when the government provides any substitute for live

testimony), and suffered trauma from her interaction with Pranzetti. See Hall, 419

F.3d at 988 (concluding that the government had good cause for not producing a

witness who was the victim of violence and feared testifying against her assailant).

AK was homeless, and the Government was unable to contact him. See id. (finding

2 Moreover, evidence that falls under a hearsay exception is often considered more reliable and is thus more likely to satisfy a releasee’s right to confrontation in revocation hearings. See Valdivia v. Schwarzenegger, 599 F.3d 984, 990 (9th Cir. 2010). LB’s contemporaneous text messages may fall under the present sense impression, see Fed. R. Evid. 803(1), and excited utterance, see Fed. R. Evid. 803(2), exceptions to hearsay. And LB’s subsequent on-scene written statement prepared by Matz may fall under the excited utterance exception.

4 good cause when the government could not locate “a homeless woman who left the

shelter where she was staying . . . and had not been heard from since”).

Third, even if the district court improperly denied Pranzetti the right to

recross Walecki, any error was harmless. See Delaware v. Van Arsdall, 475 U.S.

673, 684 (1986) (holding that the factors to consider in determining harmlessness

of a district court’s refusal to allow recross examination include “the importance of

the witness’ testimony in the prosecution’s case, whether the testimony was

cumulative, the presence or absence of evidence corroborating or contradicting the

testimony of the witness on material points, the extent of cross-examination

otherwise permitted, and . . . the overall strength of the prosecution’s case”).

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Related

Callan v. Wilson
127 U.S. 540 (Supreme Court, 1888)
Schick v. United States
195 U.S. 65 (Supreme Court, 1904)
Gagnon v. Scarpelli
411 U.S. 778 (Supreme Court, 1973)
Delaware v. Van Arsdall
475 U.S. 673 (Supreme Court, 1986)
United States v. Rickey Dean Simmons
812 F.2d 561 (Ninth Circuit, 1987)
United States v. Daniel Douglas Martin
984 F.2d 308 (Ninth Circuit, 1993)
United States v. Jose Romero Liero
298 F.3d 1175 (Ninth Circuit, 2002)
United States v. William Lewis Hall
419 F.3d 980 (Ninth Circuit, 2005)
United States v. Perez
526 F.3d 543 (Ninth Circuit, 2008)
United States v. Brian Charette
893 F.3d 1169 (Ninth Circuit, 2018)
United States v. Patrick Henderson
998 F.3d 1071 (Ninth Circuit, 2021)
United States v. Jonathan Oliver
41 F.4th 1093 (Ninth Circuit, 2022)
United States v. Comito
177 F.3d 1166 (Ninth Circuit, 1999)
Valdivia v. Schwarzenegger
599 F.3d 984 (Ninth Circuit, 2010)

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