United States v. Jackson
United States Court of Appeals for the Second Circuit
368 F.3d 59 (2004)
ATF agents found ammunition in Aaron Jackson's (defendant) apartment safe, and the government charged him with possession of ammunition by a convicted felon, relying solely on a certified copy of a 1984 New York City judgment convicting a person named Aaron Jackson of weapon and drug offenses, with no fingerprint, DNA, or other evidence linking the defendant to that specific prior conviction. Jackson presented no defense witnesses, his counsel argued in closing that the government had not proven he was the same Aaron Jackson from 1984, and the jury convicted him; he appealed the sufficiency of the identity evidence.
Whether a certified copy of a prior conviction naming a common name, without fingerprint, DNA, or other identifying evidence, is sufficient to prove beyond a reasonable doubt that the defendant is the same person previously convicted, as required for a felon-in-possession charge.