United States v. Grady
United States Court of Appeals for the Second Circuit
544 F.2d 598 (2d Cir. 1976)
Frank Grady and John Jankowski (defendants) were charged with conspiring to violate federal firearms law; Jankowski, a licensed dealer, allegedly made false logbook entries about firearms Grady carried to Northern Ireland. The prosecution introduced records from the Royal Ulster Constabulary, a Northern Irish government agency, showing the firearms were later found in Northern Ireland, to corroborate that the guns had actually traveled there after purchase. The trial court admitted the records under the public records hearsay exception, and Grady and Jankowski were convicted and appealed.
Whether reports of a law enforcement agency are admissible under the public records hearsay exception, Rule 803(8)(B), if they do not detail observations of the defendant's own commission of the crime.