All 4 defendants were convicted at trial, and 3 complained on appeal that the trial court's admission of a post-arrest statement by the 4th defendant -- the sole piece of direct evidence indicating that the conspirators may have intended to use force, rather than mere trickery, to obtain their goal -- violated their Confrontation Clause rights in light of Crawford. The Government conceded the Crawford error, but argued that the error was harmless. The Circuit disagreed, finding that the error was not harmless as to all 3, and ordering new trials for 2 (the other defendant did even better -- the Court ruled that without considering the Crawford-barred hearsay, the evidence was insufficient to sustain the conviction, and thus dismissed the charge against this defendant).
The opinion is well written but breaks no new legal ground. Those interested in harmless error analysis as applied to a Crawford error in particular may find it useful. The opinion also cleanly illustrates the difference between harmless error analysis and sufficiency-of-the-evidence analysis, as it concludes with respect to 2 defendants that although the Crawford error was not harmless (thus warranting a new trial), the evidence apart from the improperly admitted hearsay statement was sufficient to sustain their convictions. In any event, it is always refreshing to see the Court actually impose a remedy for a Crawford violation.