United States v. Urbanik – Case Brief Summary (Federal Court)

In United States v. Urbanik, 801 F.2d 692, 698 (4th Cir. 1986), the Fourth Circuit similarly concluded that a co-conspirator's statements identifying the defendant as his supplier made while lifting weights with a friend was not in furtherance of the conspiracy.

There, the court concluded that the co-conspirator's statement was no more than a casual aside to the discussion of the defendant's weight-lifting abilities. Id.