Evidence, Authentication of
Unless otherwise indicated, all indented material is copied directly from the court’s opinion.
‘Decisions of the Tennessee Supreme Court
Decisions of the Tennessee Court of Criminal Appeals
State v. Atkins, No. E2022-01027-CCA-R3-CD, p. 18 (Tenn. Ct. Crim. App. Aug. 21, 2023).
Whether evidence has been sufficiently authenticated is within the trial court’s sound discretion, and its decision will not be overturned absent an abuse of discretion. See id.
State v. Hite, No. W2022-00678-CCA-R3-CD, p. 17 (Tenn. Ct. Crim. App. July 19, 2023).
Whether evidence has been sufficiently authenticated is within the trial court’s sound discretion, and its decision will not be overturned absent an abuse of discretion. See State v. Mickens, 123 S.W.3d 355, 376 (Tenn. Crim. App. 2003).
State v. Meadows, No. M2021-01357-CCA-R3-CD, p. 6 (Tenn. Ct. Crim. App. Feb. 28 2023).
Whether evidence has been sufficiently authenticated is within the trial court’s sound discretion, and its decision will not be overturned absent an abuse of discretion. See State v. Mickens, 123 S.W.3d 355, 376 (Tenn. Crim. App. 2003).
State v. Winston, No. W2021-01315-CCA-R3-CD, p. 27-28 (Tenn. Ct. Crim. App. Dec. 14, 2022).
“The requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to the court to support a finding by the trier of fact that the matter in question is what its proponent claims.” Tenn. R. Evid. 901(a). Therefore, the question of whether tangible evidence has been properly authenticated is left to the discretion of the trial court. State v. Cannon, 254 S.W.3d 287, 295 (Tenn. 2008) (citing State v. Scott, 33 S.W.3d 746, 752 (Tenn. 2000); State v. Beech, 744 S.W.2d 585, 587 (Tenn. Crim. App. 1987)). The trial court’s determination will not be disturbed in the absence of a clearly mistaken exercise of such discretion. State v. Holbrooks, 983 S.W.2d 697, 701 (Tenn. Crim. App. 1998) (citing Beech, 744 S.W.2d at 587). Therefore, we will not reverse unless the “‘court applied an incorrect legal standard, or reached a decision which is against logic or reasoning that caused an injustice to the party complaining.’” State v. Shirley, 6 S.W.3d 243, 247 (Tenn. 1999) (quoting State v. Shuck, 953 S.W.2d 662, 669 (Tenn. 1997)).
State v. Murray, No. M2021-00688-CCA-R3-CD, p. 9-10 (Tenn. Ct. Crim. App. Nov. 30, 2022).
Both Rule 901 and the common law designate the trial court as the “arbiter of authentication issues,” and, accordingly, that court’s ruling will not be disturbed absent a showing that the court clearly abused its discretion. See Tenn. R. Evid. 901, Advisory Comm’n Comments; State v. Mickens, 123 S.W.3d 355, 376 (Tenn. Crim. App. 2003). An abuse of discretion occurs when the trial court applies an incorrect legal standard or reaches a conclusion that is “illogical or unreasonable and causes an injustice to the party complaining.” State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), overruled on other grounds by State v. Patterson, 564 S.W.3d 423, 433 (Tenn. 2018); see State v. Shirley, 6 S.W.3d 243, 247 (Tenn. 1999).
State v. Holmes, No. E2021-01489-CCA-R3-CD, p. 15 (Tenn. Ct. Crim. App. Nov. 7, 2022).
Both Rule 901 and the common law designate the trial court as the “arbiter of authentication issues,” and, accordingly, that court’s ruling will not be disturbed absent a showing that the court clearly abused its discretion. See Tenn. R. Evid. 901, Advisory Comm’n Comments; State v. Mickens, 123 S.W.3d 355, 376 (Tenn. Crim. App. 2003). An abuse of discretion occurs when the trial court applies an incorrect legal standard or reaches a conclusion that is “illogical or unreasonable and causes an injustice to the party complaining.” State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), overruled on other grounds by State v. Patterson, 564 S.W.3d 423, 433 (Tenn. 2018); see State v. Shirley, 6 S.W.3d 243, 247 (Tenn. 1999).
State v. Burgins, No. E2021-00620-CCA-R3-CD, p. 32 (Tenn. Ct. Crim. App. June 28, 2022).
Rule 901(a) of the Tennessee Rules of Evidence states as follows: “The requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to the court to support a finding by the trier of fact that the matter in question is what its proponent claims.” Evidence may be authenticated, in relevant part, through “[c]omparison by trier of fact . . . with specimens which have been authenticated.” Tenn. R. Evid. 901(b)(3). Rule 901(b)(3) has been limited in Tennessee’s appellate courts to authentication of a signature or handwriting using a known sample. See State v. Antonio Johnson, No. W2017-00476-CCA-R3-CD, 2018 WL 625126, at *9 (Tenn. Crim. App. Jan. 30, 2018) (collecting Court of Appeals and Court of Criminal Appeals decisions). Authentication issues are left to the discretion of the trial court. State v. Cannon, 254 S.W.3d 287, 295 (Tenn. 2008) (citing State v. Scott, 33 S.W.3d 746, 752 (Tenn. 2000); State v. Beech, 744 S.W.2d 585, 587 (Tenn. Crim. App. 1987)).
State of Tennessee v. Gonzalez-Martinez, No. E2021-00322-CCA-R3-CD, p. 7 (Ct. of Crim. App. May 2, 2022).
Both Rule 901 and the common law designate the trial court as the “arbiter of authentication issues,” and, accordingly, that court’s ruling will not be disturbed absent a showing that the court clearly abused its discretion. See Tenn. R. Evid. 901, Advisory Comm’n Comments; Mickens, 123 S.W.3d at 376. An abuse of discretion occurs when the trial court applies an incorrect legal standard or reaches a conclusion that is “illogical or unreasonable and causes an injustice to the party complaining.” State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), overruled on other grounds by State v. Patterson, 564 S.W.3d 423, 433 (Tenn. 2018); see State v. Shirley, 6 S.W.3d 243, 247 (Tenn. 1999).
State of Tennessee v. Benitez, No. M2021-00073-CCA-R3-CD, p. 26 (Tenn. Ct. Crim. App. Apr. 27, 2022).
Whether evidence has been sufficiently authenticated is within the trial court’s sound discretion, and its decision will not be overturned absent an abuse of discretion. See Mickens, 123 S.W.3d at 376.
State of Tennessee v. Berry, No. M2020-00250-CCA-R3-CD (Tenn. Ct. Crim. App. Feb. 10, 2022).
Whether evidence has been sufficiently authenticated is within the trial court’s sound discretion, and its decision will not be overturned absent an abuse of discretion. See State v. Mickens, 123 S.W.3d 355, 376 (Tenn. Crim. App. 2003).
