United States v. Browne

834 F.3d 403 (2016)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

United States v. Browne

United States Court of Appeals for the Third Circuit
834 F.3d 403 (2016)

Play video

Facts

Tony Jefferson Browne (defendant) used the Facebook account name “Billy Button” to chat with 18-year-old Nicole Dalmida. Dalmida and Browne exchanged explicit photographs and eventually met in person. Browne threatened to publish Dalmida’s photographs unless Dalmida engaged in oral sex and gave Browne her Facebook password. Using Dalmida’s Facebook account, Browne solicited explicit photographs from four minors. He then threatened to publish the photographs unless the minors engaged in sexual acts with Browne and sent more explicit photographs to “Billy Button” or to Browne’s cell phone. Browne arranged to meet three of the minors and sexually assaulted one of them. Browne was arrested and charged with child pornography and sexual offenses. Law-enforcement officers seized Browne’s cell phone, which contained the minors’ photographs. At Browne’s trial, Dalmida and three minors testified about their chats with “Billy Button,” and Dalmida and two minors identified Browne as “Billy Button” based on their in-person meetings. Browne testified that he owned the “Billy Button” account and the cell phone from which the photographs were recovered. Browne also admitted to chatting on Facebook with Dalmida and two of the minors, and he confirmed personal details that matched information “Billy Button” had shared in chats. The United States (plaintiff) sought to introduce five Facebook chat logs into evidence. Four of the logs reflected “Billy Button’s” chats with Dalmida and three of the minors, and one reflected a chat between Dalmida and one of the minors about Browne’s sexual assault. Facebook’s records custodian certified that the logs were made and kept by Facebook as part of Facebook’s regular practices. The government contended that the logs were self-authenticating under Federal Rule of Evidence 902(11) because they fell within the business-records exception to the hearsay rule. The district court admitted the logs into evidence. Browne was convicted, and he appealed.

Rule of Law

Issue

Holding and Reasoning (Krause, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 807,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 807,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 807,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership