United States Court of Appeals for the Eighth Circuit
585 F.2d 344 (8th Cir. 1978)
Tiburcio Rangel (defendant) was charged with fraud in connection with his seeking reimbursement from his employer, the EPA, for business trips. Rangel submitted vouchers to the EPA to obtain reimbursement and attached to each a photocopy of the ‘customer copy’ of the receipt from the hotel. The prosecution introduced these photocopies into evidence, along with the corresponding ‘merchant copy’ for each receipt, which was obtained from the hotels. The amounts on the photocopied customer copies did not match the amounts on the corresponding merchant copies. The trial court convicted Rangel. Rangel appealed on the grounds that (1) the merchant copies were not the original receipts and thus not the best evidence, and (2) the photocopies of his customer copies were not the original fraudulent customer copies and thus not the best evidence.
Rule of Law
Holding and Reasoning (Per Curiam)
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