United States v. Hall

The Third Circuit expounded on the due process and Federal Rules of Evidence standards governing the admission of voice identification evidence en route to affirming the defendant’s convictions for crimes related to filing false unemployment claims. At trial, the court permitted the defendant’s probation officer to testify that the voice in audio recordings was the defendant. The lower court also allowed the jury to hear a recording of the defendant’s post-arrest interview to enable the jury to compare the sound of the defendant’s voice. The Third Circuit held that the probation officer’s identification of the defendant’s voice satisfied due process. The officer had ample opportunity to hear and pay attention to the defendant’s voice throughout their multiple conversations. The Third Circuit also held that the trial court correctly admitted the post-arrest interview recording because the government sufficiently identified the defendant’s voice on the calls during pretrial proceedings using the probation officer’s testimony. Finally, the Third Circuit rejected the defendant’s claim that the government needed a warrant to obtain his bank records. The third-party doctrine, which provides no Fourth Amendment-protected privacy interest in bank records voluntarily conveyed to the banks, precluded relief.

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