United States v. Broadnax

23 M.J. 389 (1987)

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United States v. Broadnax

United States Court of Military Appeals
23 M.J. 389 (1987)

Facts

Army Private Lorenzo Broadnax (defendant) was accused of forging a check. At Broadnax’s court-martial, the prosecution (plaintiff) submitted a forensic laboratory report from a document examiner who had reviewed the check, examples of Broadnax’s handwriting, and examples of the checking-account owner’s handwriting. The report stated that the document examiner believed that Broadnax had written everything on the forged check except the date. The handwriting examples reviewed by the document examiner were not submitted as evidence in the trial. Broadnax objected to the report being admitted as evidence. However, the military judge admitted the report, finding that it was admissible under the public-records-and-reports exception to hearsay in Military Rule of Evidence 803(8). Broadnax was convicted. On appeal, Broadnax argued that the report should have been excluded from his trial.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

Concurrence (Cox, J.)

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