State v. Tieman
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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of murder, holding that the court did not abuse its discretion by admitting Facebook Messenger records into evidence and that there was sufficient evidence to support the jury's verdict.
On appeal, Defendant argued that the court erred in admitting Facebook Messenger records because they were not properly authenticated and that they were improperly admitted pursuant to the hearsay exception that allows for the admission of a declarant's statement of his then-existing statement of mind. The Supreme Judicial Court affirmed, holding (1) the court did not err or abuse its discretion when it found the Facebook Messenger records to be authenticated under Me. R. Evid. 901; (2) assuming that the Facebook Messenger statements were hearsay, they were improperly admitted under Me. R. Evid. 803(3), but the error was harmless; and (3) there was sufficient evidence for the jury to find Defendant guilty of murder.
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