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United States v. Evans

United States Court of Appeals for the Ninth Circuit
728 F.3d 953 (2013)


Facts

Joseph Anderson Evans Sr. (defendant) was charged with several crimes relating to his immigration status. In his defense, Evans claimed he was a US citizen and attempted to admit into evidence an Idaho birth certificate. During a pretrial hearing on whether the birth certificate was admissible, the government presented three witnesses who testified that the birth certificate was not substantively genuine, but there was no dispute that the birth certificate was an official document issued by the Idaho Bureau of Vital Records and Health Statistics. The trial court found the government’s witnesses to be credible. The court held that no reasonable person could conclude the birth certificate was substantively genuine, and it was thus inadmissible under Federal Rule of Evidence (FRE) 104. Evans was convicted, and he appealed the conviction on the grounds that the court improperly excluded his birth certificate.

Rule of Law

Issue

Holding and Reasoning (Paez, J.)

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