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United States v. Mitchell

816 F.3d 865 (2016)

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United States v. Mitchell

United States Court of Appeals for the District of Columbia Circuit
816 F.3d 865 (2016)

Facts

Sherman Mitchell (defendant) was charged with crimes related to a PCP drug-distribution ring. After seizing and sampling the drugs, Detective Joseph Abdalla could not recall whether he gave the evidence bags containing the samples to another officer or whether he handled the bags directly. This left a gap in the chain of custody before the samples reached Drug Enforcement Agency (DEA) chemist, John Liu. Despite the gap, Mitchell was convicted. On appeal, Mitchell argued that this gap caused the samples of alleged PCP not to be properly authenticated and that, therefore, the evidence should not have been admitted.

Rule of Law

Issue

Holding and Reasoning (Henderson, J.)

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