United States v. Stephens
United States Court of Appeals for the Fifth Circuit
779 F.2d 232 (1985)
The government (plaintiff) charged Columbus Schalah Stephens, Jr. (defendant) with making false statements on a federal loan application. At trial, the judge admitted government-prepared charts summarizing hundreds of complex exhibits into organized categories, instructing the jury to treat the charts only as summaries, not as independent evidence of guilt. The jury convicted Stephens, who appealed, arguing the charts were improper pedagogical devices rather than true Rule 1006 summaries, that the categories were argumentative, and that Rule 1006 only permits summaries when the underlying evidence is literally impossible to examine in court.
Whether evidentiary summaries are admissible under Federal Rule of Evidence 1006 when the underlying evidence is voluminous and merely inconvenient, rather than literally impossible, to examine in court.