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Parker v. State

Delaware Supreme Court
85 A.3d 682 (2014)


Facts

Tiffany Parker (defendant) got into a physical altercation with another woman, Sheniya Brown. Parker defended herself at trial from the assault charge by claiming her actions were justified as self-defense. To contradict this claim, the state introduced Facebook posts purportedly written by Parker that Brown reposted. To authenticate the posts, the state presented testimony from Brown about how she viewed and shared Parker’s post and about the post itself. These posts had distinctive characteristics consistent with being from Brown’s account. The posts referenced a fight with another woman on the same day as Parker and Brown’s altercation took place. Over Parker’s objection, the trial court admitted the posts into evidence. Following her conviction, Parker appealed on the basis that the Facebook posts had not been properly authenticated.

Rule of Law

Issue

Holding and Reasoning (Ridgely, J.)

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