United States v. Towns

Investigating a methamphetamine conspiracy, a police officer gathered pseudoephedrine purchase records that state and federal law require pharmacies to keep, then compiled spreadsheets logging Melvin Towns's (defendant) and others' purchases across multiple pharmacies. At trial, the government introduced the spreadsheets under the business-records exception through the officer, who had received self-authenticating certifications from each pharmacy's records custodian. Towns was convicted of conspiracy to manufacture methamphetamine and appealed, arguing the spreadsheets did not qualify as business records and that admitting them violated his Sixth Amendment confrontation rights.