United States v. Laster case brief

United States v. Laster case brief summary
258 F.3d 525 (6th Cir. 2001), cert. denied, 534 U.S. 1151 (2002)

CASE SYNOPSIS

Defendants appealed their convictions and sentences for drug offenses by the United States District Court for the Western District of Kentucky at Owensboro.

CASE FACTS
Defendants, convicted of manufacturing methamphetamine in violation of 21 U.S.C.S. § 846and of possessing methamphetamine with the intent to distribute in violation of 21 U.S.C.S. § 841(a)(1) and 18 U.S.C.S. § 2, claimed the district court improperly admitted hydroidic acid purchase records under the business records exception, Fed. R. Evid. 803(6).

DISCUSSION

• The appeals court said that while the records were not admissible as a business record because the government agent testifying was not familiar with the seller's record keeping system, the records were admissible under the residual exception of Fed. R. Evid. 807 as they were material, more probative on the point for which they were offered than any other reasonably available evidence, and their admission best served the interest of justice. 
• The appeals court rejected defendants' claim that the determination that they were manufacturing D-methamphetamine rather than L-methamphetamine was improperly made by the court, holding that such determination was not an aggravating factor which required a decision by the jury as it did not increase the penalty for the crime beyond the statutory maximum.

CONCLUSION
The judgment was affirmed.

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