Wednesday, December 18, 2013

Griffin v. State case brief

Griffin v. State case brief summary
19 A.3d 415 (2011)


CASE SYNOPSIS
Defendant sought reversal of his convictions. The Court of Special Appeals (Maryland) his convictions. Defendant's petition for writ of certiorari and the State's cross-petition were granted.

CASE FACTS
Defendant contended that the trial judge abused his discretion in admitting, without proper authentication, what the State alleged were several pages printed from defendant's girlfriend's MySpace profile. The State attempted to authenticate the pages, as belonging to defendant's girlfriend, through the testimony of the lead investigator in the case. Defendant argued that the trial court erred in admitting the evidence, because the State failed to offer any extrinsic evidence describing MySpace, as well as indicating how the lead investigator obtained the pages in question and adequately linking both the profile and a posting threatening a key State's witness to the girlfriend.

DISCUSSION

  • The court of appeals held that the pages allegedly printed from defendant's girlfriend's MySpace profile were not properly authenticated pursuant to Md. R. 5-901. 
  • The picture of the girlfriend, coupled with her birth date and location, were not sufficient "distinctive characteristics" on a MySpace profile to authenticate its printout.

CONCLUSION
The judgment of the court of special appeals was reversed and the case was remanded with instructions to reverse the judgment of the trial court and remand to that court for a new trial.

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