USA v. Williams, No. 22-10316 (5th Cir. 2023)
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Defendant was convicted of sex trafficking of a child in violation of 18 U.S.C. Section 1591(a)(1) and (b)(2). On appeal, he challenged the introduction of evidence pulled from his cellphone using Cellebrite technology. He claimed that the district court erred by permitting a police investigator to introduce the Cellebrite extract without first being qualified as an expert under Federal Rule of Evidence 702.
The Fifth Circuit affirmed. The court explained that when law enforcement uses Cellebrite to pull information from a phone, and a lay juror would require no additional interpretation to understand that information, the party does not need to introduce the evidence through an expert. The court explained that all the investigator testified to was how he downloaded the information from the phones using Cellebrite technology. At no point did he speak to the reliability of the software, except that he double-checked some of the reports by looking directly at the source material in the phones themselves. To that end, he did not state any information on how Cellebrite operated in a technical sense, nor information that was beyond the knowledge of an average cell phone user. Without a showing of specialized knowledge, the mere use and understanding of a Cellebrite extract at trial is insufficient to require an expert. Operating a Cellebrite device and understanding its report require knowledge in the realm of a reasonably tech-savvy layperson, regardless of the investigator’s testimony that he was a “certified” operator and analyzer.
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