U.S. v. Childs

Citation
United States v. Childs, 5 F.3d 1328 (9th Cir. 1993).

Factual Background
Between May and July of 1987, five vehicles were reported stolen in Arizona. During this same period of time, Defendant Craig Lee Childs registered these five cars in Calgary, Alberta, Canada, using the name Craig Lee Connors. He was also seen test-driving one of the stolen automobiles in Arizona.

A jury trial was held in federal court in Phoenix, Arizona. Childs was convicted of possession of stolen automobiles, and sentenced to one year incarceration and five years of probation.

Childs appealed to dismiss his conviction and sentence, arguing, inter alia, that (1) documents related to stolen automobiles were improperly admitted; and (2) copies of certain documents should not have been admitted.

Appellate Court Proceedings
The Court of Appeals found the following:

Documents as business records
Childs argued that the district court should not have allowed the admission of several documents as business records. The appellate court held that they were properly admitted under the business records exception to the hearsay rule.

Copies of documents
Childs also argued that copies of several documents kept by automobile dealerships also should not have been admitted into evidence. However, the Court of Appeals found that they were admissible under Federal Rule of Evidence 1002.