State v. Lopez-Ramos

Summary

The Minnesota Supreme Court held that admitting a criminal defendant’s statements translated by a foreign-language interpreter did not violate the Sixth Amendment’s Confrontation Clause. The court treated the defendant as the declarant and the interpreter as a language conduit, so the statements were also admissible as admissions by a party-opponent under Minnesota Rule of Evidence 801(d)(2)(A). The court affirmed the court of appeals.

Holdings

1. Use of a foreign-language interpreter to translate a defendant's statement from one language to another does not implicate the Confrontation Clause because the interpreter is not a witness who bears testimony against the defendant; the defendant remains the declarant of the translated statement.
2. The translated statements were not hearsay because Lopez-Ramos was their declarant and they were offered against him as statements of a party-opponent under Minn. R. Evid. 801(d)(2)(A).

Questions Presented

1. Whether admitting a criminal defendant's statements made through a foreign-language interpreter, without calling the interpreter to testify, violates the Sixth Amendment Confrontation Clause.
2. Whether the defendant's translated statements are inadmissible hearsay when offered by the State in the defendant's criminal prosecution.

Disposition

affirmed