United States v. Rangel

Tiburcio Rangel (defendant) sought reimbursement from his employer, the EPA, for business travel by submitting vouchers with photocopies of the customer copies of hotel receipts. The amounts on these photocopies didn't match the amounts on the corresponding merchant copies obtained directly from the hotels, and Rangel was convicted of fraud; he appealed, arguing neither the merchant copies nor the photocopies of his own altered customer copies were the actual originals required under the best evidence rule.