Butts
United States v. Butts
Opinion
Lead Opinion
MEMORANDUM ***
Steven Butts appeals his conviction and sentence for conspiracy, armed bank robbery, and possessing, carrying, and brandishing a firearm during a crime of violence in violation of 18 U.S.C. §§ 371 , 924(c), and 2113(a), (d). We affirm.
Butts first argues that the letter to Andre Faison (the “Faison letter”) was not adequately authenticated because Faison testified that he did not know Butts’s handwriting. We review for abuse of discretion whether evidence was adequately authenticated, United States v. Workinger, 90 F.3d 1409, 1415 (9th Cir.1996), and we conclude that the district court did not abuse its discretion here.
Authentication of evidence “is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims.” Fed.R.Evid. 901(a). A document “may be shown to have emanated from a particular person by virtue of its disclosing knowledge of facts known peculiarly to him.” Fed.R.Evid. 901, Advisory Committee Notes Example (4). “The government need only make a prima facie showing of authenticity so that a reasonable juror could find in favor of authenticity or identification.” Workinger, 90 F.3d at 1415 (internal…