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United States v. Buchanan

United States Court of Appeals for the Eighth Circuit
604 F.3d 517 (2010)


Facts

Ronald Buchanan (defendant) was arrested for crimes involving narcotics. During his arrest, police found a key on Buchanan’s person. The key had the number 2010 inscribed on it. The key fit into a safe that also was inscribed with the number 2010 inside. In addition to cocaine and other evidence inside the safe, the police found an instruction manual to the safe stating that the safe was a 2010 model. The police did not seize the safe itself, and the safe was not present at Buchanan’s trial, but the law-enforcement officers testified that the safe was inscribed with the number 2010, and the government admitted into evidence the manual. Following his conviction, Buchanan appealed, arguing that the best-evidence rule required the actual safe to have been presented at trial rather than testimony about the number inside the safe because the number 2010 was a writing.

Rule of Law

Issue

Holding and Reasoning (Smith, J.)

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