United States v. Waddell

• Court: Court of Appeals for the Fifth Circuit
• Decided: August 8, 2025
• Docket: 24-10814
• Status: Unpublished

Opinion

Case: 24-10814 Document: 60-1 Page: 1 Date Filed: 08/08/2025

United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit No. 24-10814 Summary Calendar FILED ____________ August 8, 2025 Lyle W. Cayce United States of America, Clerk

Plaintiff—Appellee,

versus

Rachel Lynn Waddell,

Defendant—Appellant. ______________________________

Appeal from the United States District Court for the Northern District of Texas USDC No. 2:23-CR-69-5 ______________________________

Before Davis, Smith, and Higginson, Circuit Judges. Per Curiam: * Rachel Lynn Waddell was convicted by a jury of conspiracy to distribute and to possess with intent to distribute fentanyl in violation of 21 U.S.C. § 846. Waddell challenges an evidentiary ruling and notes a clerical error in the judgment.

_____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 24-10814 Document: 60-1 Page: 2 Date Filed: 08/08/2025

No. 24-10814

Waddell argues that the Government did not properly authenticate photographs of images secured from the PillEye application on her phone. Given the low bar for satisfying that burden, the Government adequately authenticated the images. See United States v. Okulaja, 21 F.4th 338, 345 (5th Cir. 2021); United States v. Jackson, 636 F.3d 687, 693 (5th Cir. 2011). Similarly, given the deference afforded to district courts in making evidentiary rulings, Waddell’s challenge to the relevancy and prejudicial value of the photographs fails. See Fed. R. Evid. 401, 403; United States v. Fields, 483 F.3d 313, 354 (5th Cir. 2007); United States v. Pace, 10 F.3d 1106, 1115–16 (5th Cir. 1993). Accordingly, the judgment of the district court is AFFIRMED. Our decision does not affect the ability of the parties to request the district court’s correction of any clerical error under Federal Rule of Criminal Procedure 36. See United States v. Nagin, 810 F.3d 348, 353–54 (5th Cir. 2016).