United States v. Dockins
United States Court of Appeals for the Fifth Circuit
986 F.2d 888 (5th Cir. 1993)
Dockins (defendant) was tried for possessing a firearm as a felon; the prosecution wanted to show he had previously been convicted under the alias Carl Smith and offered a fingerprint card bearing a Denver Police Department label. Witnesses testified the signature and fingerprints on the card matched Dockins, but their knowledge of where the card actually came from was based solely on the label printed on the card itself; the trial court admitted the card, Dockins was convicted, and he appealed on authentication grounds.
Whether a document is properly authenticated when the authenticating witnesses have no independent knowledge of its origin beyond what is written on the document itself.