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United States v. Woods

United States Court of Appeals for the Third Circuit
321 F.3d 361 (2003)


Facts

Nafis Woods (defendant) was convicted of the federal crime of carjacking, which required that the vehicle was transported in interstate commerce. To prove this, the government proffered the testimony of FBI Special Agent Jay Heine, an agent with four years of experience in investigating interstate-commerce matters. Special Agent Heine testified that he was familiar with vehicle identification numbers (VINs) and used a database maintained by the National Insurance Crime Bureau (NICB) to trace the vehicle’s VIN to a manufacturing plant in Tarrytown, New York. Woods objected to the testimony as hearsay. The district court overruled and admitted the testimony. Following his conviction, Woods appealed on the basis that Heine’s testimony about the VIN was inadmissible hearsay.

Rule of Law

Issue

Holding and Reasoning (Becker, C.J.)

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