United States Second Circuit

Conviction for unlawful transfer of a false identification document is vacated and remanded for a new trial, where: 1) the district court permitted the introduction of a social media page that was created by defendant, without satisfying the authentication requirement of Rule 901 of the Federal Rules of Evidence; and 2) this evidentiary ruling was an abuse of the district court's discretion and was not harmless.

Appellate Information

• Decided 10/03/2014
• Published 10/03/2014

Judges

• Livingston

Court

• United States Second Circuit

Counsel