United States v. Stephens
United States Court of Appeals for the Fifth Circuit
779 F.2d 232 (1985)
The United States government (plaintiff) charged Columbus Schalah Stephens, Jr. (defendant) with making false statements on his application for a federal loan. At trial, the judge admitted government charts as evidence. The charts summarized hundreds of complex trial exhibits and grouped them into categories. The judge instructed the jury to consider the charts solely as summaries and not as real evidence of the alleged crime. The jury convicted Stephens. On appeal to the United States Court of Appeals for the Fifth Circuit, Stephens argued the charts were inadmissible because: (1) they were pedagogical devices and not summaries under Federal Rule of Evidence 1006, (2) the categories contained in the charts were impermissibly argumentative, and (3) Rule 1006 allows the use of summaries only if exhibits are impossible to examine in the courtroom.
Rule of Law
Holding and Reasoning (Williams, J.)
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