United States v. Iriele
United States Court of Appeals for the Eleventh Circuit
977 F.3d 1155 (2020)
- Written by Nathan Benedict, JD
Facts
Donatus Iriele (defendant) was charged with numerous crimes, including money laundering. At trial, the government introduced a handwritten ledger seized from Iriele’s home showing various transactions. A law-enforcement officer who had been involved in investigating Iriele authenticated the ledger by testifying that the handwriting in the ledger belonged to Iriele. Iriele was convicted and appealed. He argued that the officer should not have been permitted to authenticate his handwriting under Federal Rule of Evidence 901(b)(2), which provides that a lay witness cannot authenticate handwriting if the witness’s familiarity with the handwriting was acquired for purposes of litigation.
Rule of Law
Issue
Holding and Reasoning (Carnes, J.)
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