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Ricketts v. City of Hartford

United States Court of Appeals for the Second Circuit
74 F.3d 1397 (1996)


Facts

Weldon L. Ricketts (plaintiff) sued the City of Hartford (defendant) for violations of his constitutional rights. Ricketts, a Black man, was coaching a soccer team in a park when numerous, nearly all White, police officers came by chasing Timothy Moore, a Black man suspected of assault and attempted robbery. The police-officer testimony and Ricketts’s testimony diverged after this, but Ricketts testified that the police officers were beating Moore when they caught him and that when Ricketts questioned them, they beat Ricketts too. To corroborate his testimony, Ricketts sought to admit a tape recording of the events in which a man stated, “Run him over.” Ricketts claimed that a police officer named Davis, who Ricketts said was his principal aggressor, said this. The court held a hearing to determine the admissibility of the tape. During the hearing, Davis denied making the statement or even hearing it. The court found the tape inadmissible, holding that Ricketts failed to properly authenticate the tape. After the court dismissed Ricketts’s complaint, Ricketts appealed, arguing that the court erred in finding the tape inadmissible.

Rule of Law

Issue

Holding and Reasoning (Mahoney, J.)

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