United States v. Parkinson

CourtCourt of Appeals for the First Circuit
DecidedMarch 30, 1993
Docket91-2233
StatusPublished

This text of United States v. Parkinson (United States v. Parkinson) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Parkinson, (1st Cir. 1993).

Opinion

USCA1 Opinion


March 30, 1993 [NOT FOR PUBLICATION]

UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
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No. 91-2233

UNITED STATES,

Appellee,

v.

KEITH JAMES PARKINSON,

Defendant, Appellant.

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APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE

[Hon. D. Brock Hornby, U.S. District Judge]
___________________

___________________

Before

Breyer, Chief Judge,
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Campbell, Senior Circuit Judge,
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and Cyr, Circuit Judge.
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___________________

Christopher W. Dilworth and Dilworth, White & Brandt on
________________________ __________________________
brief for appellant.
Richard S. Cohen, United States Attorney, and F. Mark
_________________ ________
Terison, Assistant United States Attorney, on brief for appellee.
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__________________

__________________

Opinion on Rehearing

Per Curiam. Keith Parkinson appeals from his conviction
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on a single count of bank robbery, in violation of 18 U.S.C.

2113(a). He raises four issues, two involving evidentiary

rulings at trial and two pertaining to his sentence. We

affirm the conviction but remand for resentencing.1

I. Background
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Shortly before noon on February 15, 1990, a man robbed

the Casco Northern Bank's West End branch in Portland, Maine.

He handed the teller a note, written on the back of a bank

form, which read, "Put all your hundreds and fifties on the

counter now." The teller complied, and the man escaped with

$1300. At trial, the teller, Sara Plourd, identified

defendant as the individual in question. So did Amy Bolduc,

another teller who had been seated adjacent to Plourd at the

time of the robbery. (Both had separately identified

defendant earlier in a photographic line-up prepared by the

FBI.) Defendant was also identified by Roger Sabin, an

employee of a restaurant located near the bank, as the

individual who arrived shortly after 11:00 on the morning of

the robbery, drank two beers while looking out the window in

the bank's direction, and then departed. Finally, an FBI

expert document examiner, who had compared the robbery note

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1. On December 4, 1992, we issued an opinion in this case
affirming both the conviction and the sentence. In response
to defendant's petition for rehearing, we have vacated that
earlier opinion and issued the instant one in its stead.

-2-

with handwriting exemplars obtained from defendant, testified

that the note and the exemplars had been written by the same

person. Following the one-day trial, defendant was convicted

and sentenced to twenty years in prison.

II. Authentication of Robbery Note
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We first address defendant's argument that the

government presented an inadequate foundation for admission

of the robbery note. At trial, Sara Plourd was asked if she

recognized the note and responded: "Yes, that's the note that

the man gave me." And following the note's admission into

evidence, the FBI document examiner identified it (by means

of his initials which he had written on the back) as the one

that had been sent to him for examination; as mentioned, he

also identified the writing as that of defendant. As he did

below, defendant now argues that the court erred in admitting

the note because the government failed to prove an

uninterrupted chain of custody. We review the district

court's ruling for abuse of discretion, see, e.g., United
___ ____ ______

States v. Collado, 957 F.2d 38, 39 (1st Cir. 1992).
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Defendant's claim falters for the reasons expressed in

United States v. Abreu, 952 F.2d 1458, 1467 (1st Cir.), cert.
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denied, 112 S. Ct. 1695 (1992). Where "the offered evidence
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is of the type that is not readily identifiable or is

susceptible of alteration, a testimonial tracing of the chain

of custody is necessary." Id. The purpose thereof "is to
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-3-

render it improbable that the original item has been

exchanged with another or has been tampered with or

contaminated." Id. Yet no testimony as to chain of custody
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is necessary where the evidence "is readily identifiable by a

unique feature or other identifying mark." Id.; accord,
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e.g., United States v. Hernandez-Herrera, 952 F.2d 342, 344
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(10th Cir. 1991) (where "documents are uniquely identifiable

and relatively resistant to change, the establishment of a

chain of custody is not necessary"); see also Fed. R. Evid.
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901(b)(1) & (4). It is not disputed that the robbery note

here fell within this latter category. See, e.g., M. Graham,
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