Ninth Circuit -- RICKY WAHCHUMWAH V. USA

No 4A violation in use of buttonhole A/V recorder by undercover agent.  Surveillance wasn't long enough to trigger Jones analysis.

Offering to sell eagle tail feathers is a lesser included offense within actually selling -- Blockberger requires that both offenses have an element exclusive to them.

Photos of birds not unduly prejudicial.

No Confrontation Clause issue in not allowing deft to confront tipper - the allegations weren't in for the truth of the matter asserted, they were just cited to prove legitimacy of the investigation.


RICKY WAHCHUMWAH V. USA