United States v. Sims
United States District Court for the Eastern District of Michigan
113 F. Supp. 2d 1130 (2000)

- Written by Sean Carroll, JD
Facts
A confidential informant bought drugs from Deshawn Sims (defendant) under the supervision of the Drug Enforcement Administration (DEA). The DEA recorded the conversation that occurred when the drugs were purchased. Sims was charged with various drug crimes. At trial, the prosecution (plaintiff) introduced the recording of the conversation. The prosecution called DEA agent Daniel Krause to testify that he heard Sims’s voice when Sims was processed at the DEA office after his arrest. Krause testified that Sims’s voice was distinctive. Finally, Krause testified that the voice on the recording was Sims’s. Sims was convicted. Sims filed a motion to invalidate the convictions, arguing that the prosecution failed to properly authenticate his voice on the recording under Federal Rule Evidence 901.
Rule of Law
Issue
Holding and Reasoning (Feikens, J.)
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