United States v. Towns
United States Court of Appeals, Fifth Circuit
718 F.3d 404 (2013)
- Written by Rose VanHofwegen, JD
Facts
A police officer identified people suspected of purchasing pseudoephedrine in a conspiracy to manufacture methamphetamines and asked multiple pharmacies for their purchase records (which state and federal law requires pharmacies to keep). The officer compiled spreadsheets logging purchases that Melvin Towns (defendant) and others had made from multiple pharmacies. The prosecution charged Towns with conspiracy to manufacture and sell methamphetamines and introduced the spreadsheets under the business-records exception through the police officer, who received and reviewed the pharmacy records and their self-authenticating statements from the records custodians of the pharmacies. Towns appealed his conviction, arguing that purchase-log spreadsheets did not qualify under the business-records exception and violated his Sixth Amendment rights under the Confrontation Clause.
Rule of Law
Issue
Holding and Reasoning (Jones, J.)
Dissent (Graves, J.)
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