United States v. Garces

32 M.J. 345, 1991 CMA LEXIS 469, 1991 WL 86296
CourtUnited States Court of Military Appeals
DecidedMay 29, 1991
DocketNo. 64,545; CM 8802637
StatusPublished
Cited by40 cases

This text of 32 M.J. 345 (United States v. Garces) is published on Counsel Stack Legal Research, covering United States Court of Military Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Garces, 32 M.J. 345, 1991 CMA LEXIS 469, 1991 WL 86296 (cma 1991).

Opinions

Opinion of the Court

COX, Judge:

Contrary to appellant’s pleas, a general court-martial convicted him of one specification of resisting apprehension and five specifications of larceny, in violation of Articles 95 and 121, Uniform Code of Military Justice, 10 USC §§ 895 and 921, respectively. The court-martial sentenced him to be confined and to forfeit $1500.00 pay per month for 3 years, and to be dismissed from the Army. The convening authority approved the sentence, and the Court of Military Review affirmed the findings and sentence in a short-form opinion.

We granted appellant’s petition for review to consider whether the military judge erred by admitting computer generated documents as exceptions to the hearsay rule and whether he should have declared a mistrial.1 Finding no error, we affirm.

I

The Government tried this case on the theory that appellant had obtained the credit card numbers of two brother officers, Captain N and Chief Warrant Officer B; ordered a large number of items by telephone; and used the credit cards to pay for the orders. Appellant began his scheme by renting a mail box in the name of Captain N from a private mail shipping and receiving company called The Post Box. He used the box as a mailing address to receive goods he ordered using Captain N’s VISA card number. When the items arrived, he signed the delivery logs using Captain N’s name.

At some point appellant also obtained CWO B’s credit card number, and he informed the proprietors of The Post Box that he would be receiving packages for CWO B at the box. Then he used CWO B’s credit card number to order a leather jacket, which was delivered to the box and receipted for by appellant as Captain N. He also ordered dietary supplements and a “muscle pump” using the same credit card.

Before the last items were delivered, Captain N and CWO B disputed the charges on their respective bills, and an investigation led to The Post Box, where agents of the Criminal Investigation Command (CID) seized the dietary supplements and muscle pump. They also asked the manager to notify them when the person representing himself as “Captain N” reappeared.

About 1 week later, appellant came to The Post Box to close the box. As arranged, the manager called the CID. When the agents arrived, he identified appellant for them. Appellant saw the agents and fled, being apprehended about 2 blocks away. At the time he was wearing a name tag on his uniform that had “N” on it rather than his own name.

During an interview with the CID agents, appellant admitted the essential facts of his scheme, including placing the orders using the credit card numbers of [347]*347Captain N and CWO B. After consenting to a search of his car, appellant turned over to CID a notebook with B’s credit card number written in it. Later on, he turned over a leather jacket similar to that ordered on B’s credit card.

To connect appellant to those items, the Government offered documentary evidence tracing the flow of telephone orders for the goods. This evidence included documents showing the copies of sales drafts and invoices charged to the accounts of Captain N and CWO B; disputes on charges to the credit cards by Captain N and CWO B; “chargebacks” (i.e., losses) to the firms which supplied the goods; the signature log maintained by The Post Box showing that various packages had been receipted for by “Captain N”; a tracer form and driver’s log for a leather jacket; and documents showing the exchange of that jacket by the vendor. Over timely objection, the military judge admitted the documents as records of regularly conducted activity under Mil.R.Evid. 803(6), Manual for Courts-Martial, United States, 1984.2

In support of its position that the documents were admissible, the Government called officers from the card-issuing banks3 to explain the procedures followed by those institutions when they received notification of the unauthorized use of the credit cards. Next, employees of the corporations that looked into claims of improper credit-card use described the process used to investigate disputed charges and the records (computer and otherwise) that are generated as a result of such action. Finally, employees of the merchants who sold the goods ordered by appellant testified about other documents in the sales chain. These witnesses described the process for taking credit-card orders, assessing losses to merchants, preparing shipping logs, and making tracer requests. However, they were not the persons who made the actual entries and in some cases were not even the records’ custodians.

Appellant concedes that these witnesses understood the procedures used to prepare the documents. However, citing United States v. Wilson, 1 MJ 325 (CMA 1976), he argues that this Court should require that the foundation be established by someone “intimately familiar” with the business operations of those firms for which the entries were originally made. Wilson was decided prior to adoption by the President of the Military Rules of Evidence. We must now determine the requisite foundation for admissibility under Mil.R.Evid. 803(6).

We have not directly addressed this question, but we note that the rule is in all respects identical to the corresponding Federal Rule. Thus, we look to the Federal Courts of Appeals for guidance in its application. Cf. -nited States v. Powell, 22 MJ 141 (CMA 1986); Art. 36(a), UCMJ, 10 USC § 836(a). The Courts of Appeals which have considered this question have rejected the more stringent requirement previously imposed by the common law. All that is necessary now is that the witness be generally familiar with the record-keeping system. United States v. Hathaway, 798 F.2d 902 (6th Cir.1986) and cases collected therein. For instance, in United States v. Colyer, 571 F.2d 941 (5th Cir.), cert. denied, 439 U.S. 933, 99 S.Ct. 325, 58 L.Ed.2d 328 (1978), the Government was allowed to introduce 61 Master-Card purchase tickets on the strength of the testimony of an assistant manager of the issuing bank. The bank itself did not make the sales tickets, but the officer was sufficiently familiar with the process to satisfy the court of the reliability of the information on them.

The requirement that the witness providing the foundation only be generally familiar with the process is eminently reason[348]*348able. Modern business dealings no longer rely on the quill pen or the letter press to generate documents. As the military judge observed: “[I]t appears to me that this is the nature of business today.” One cannot expect a records custodian to understand all the mechanics of data processing or the intricacies of electronic fund transfers. All that is required is that “the witness is shown not only to have knowledge of the declarant’s business, but also some knowledge of the particular activity of the business which generates the report.” See United States v. Dababneh, 28 MJ 929, 936 (NMCMR 1989). Here the witnesses showed sufficient understanding of the record systems to explain them to the military judge and to establish the reliability of the entries on the documents.

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Bluebook (online)
32 M.J. 345, 1991 CMA LEXIS 469, 1991 WL 86296, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-garces-cma-1991.