Defendant’s Post-Arrest, Pre-Presentment Confession Was Admissible

Oscar Cantu-Ramirez (“Cantu-Ramirez”), Raul Cantu-Ramirez (“Raul”), and Lauro Abel Grimaldo (“Grimaldo”) appeal their sentences and convictions relating to their alleged roles in a 16-person conspiracy to distribute tens of thousands of pounds of drugs throughout the United States. ​

The court held that the confession was voluntary under the totality of the circumstances to be considered under 18 U.S.C. § 3501(b), including the nature of the interrogation and the fact that officers did delay presentment for the purpose of interrogation. Furthermore, introduction of post-arrest statements of brother/co-defendant in joint trial with the defendant did not violate the defendant’s Confrontation Clause rights. The statements were redacted to eliminate any reference to the defendant, and the redacted statements were read to the jury in a way that did not reveal that there had been any redactions. Also, the jury was instructed the statements were to be considered only against co-defendant, and not against defendant.

Jonathan Zendeh Del Avatar

Jonathan Zendeh Del

Attorney South Texas College of Law Houston, Texas State Bar

After practicing law in Oklahoma, Jonathan returned to his native Galveston to establish Zendeh Del & Associates, PLLC, where he and his wife are law partners.

Year after year, Jonathan is named in Super Lawyers® Magazine and featured in Texas Monthly Magazine. Jonathan has achieved an AV Preeminent® Rating from Martindale-Hubbell® and has a 100% Client Review Rating. Jonathan has been named on The National Trial Lawyers’ “Top 100 Trial Lawyers” list. Jonathan has also received an Avvo Rating of 10.0 Superb for his experience, industry recognition, and professional conduct as a lawyer.

Jonathan practices in the areas of DWI/DUI defense, criminal defense, and personal injury law.

Areas of Expertise: DWI, Criminal Defense, Personal Injury




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