the target, attempted to use a debit card stolen during the May 11 robbery, and continued to participate in the conspiracy from prison by offering to pay Levatte several thousand dollars to falsely inculpate another woman in the robberies. Given this testimony as well as other evidence, there is no reasonable possibility Thomas’s statement from the holding cell contributed to the jury’s finding she was involved in the charged conspiracy. Additionally, Thomas’s false exculpatory statement was not “closely tied to” the non-conspiracy offenses with which she was convicted, and therefore “could have made little difference to the jury verdict.” See Arbolaez, 450 F.3d at 1293. Aside from the conspiracy charge, Thomas was convicted on Counts Two and Three for committing an arm h Cir.1987) (<HOLDING>). 3 . In Bonner v. City of Prichard, 661 F.2d
holding that a permanent change in income constitutes a substantial change in circumstances justifying a reduction of alimony holding court cannot change custody without showing that change is in best interests of child holding that a showing of a change in circumstances that is or is likely to be beneficial to the child may also warrant a change in custody holding an initial edwards violation was vitiated by a onenight break in interrogation a change in place of the interrogations a change of identity of the interrogators and a change of the subject matter of the interrogations holding that a change of venue has no affect on the applicable state law and that change of venue is but a change of courtrooms