United States v. Summers, No. 06-5009 (4th Cir. 2011)
Annotate this CaseDefendant appealed his drug trafficking and firearm convictions. Defendant contended that the district court erroneously admitted into evidence a jacket recovered from the vicinity of the arrest. Defendant also contended the district court compounded its error by declining to exclude expert evidence concerning DNA testing performed on the jacket, together with evidence documenting the jacket's handling and custody during the testing process. The court held that the district court did not abuse its discretion in ruling that admission of the jacket into evidence satisfied the Fed. R. Evid. 901(a) threshold. The court also held that if the district court's admission of an expert's report constituted error, it was harmless beyond a reasonable doubt. Accordingly, the court affirmed the judgment.
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