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United States v. Browne

834 F.3d 403, 405-11 (3d Cir. 2016)

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United States v. Browne

United States Court of Appeals for the Third Circuit

834 F.3d 403, 405-11 (3d Cir. 2016)

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.)

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