Internet Chats — Party’s Statements Are Admissions and Unidentified Counterparties’ Statements Not Hearsay when Admitted to Provide Context for Party’s Statements

United States v. Beckman, 2015 U.S. App. LEXIS 12238 (6th Cir. July 13, 2015):

III. Admission of Chats with Unidentified Individuals


Beckman also claims that the chats with unidentified persons constituted inadmissible hearsay. But Beckman concedes he is jimmyab2010; thus his portion of the chats were admissions of a party opponent, Fed. R. Evid. 801(d)(2)(A), not hearsay. The other parties' portions of the chats were properly admitted to provide context to Beckman's own statements. See United States v. Henderson, 626 F.3d 326, 336-37 (6th Cir. 2010) (observing that statements Henderson made during recorded telephone conversations were non-hearsay admissions under Fed. R. Evid. 801(d)(2)(A), and the statements made by others were not admitted [*10]  to show the truth of the matter asserted, but to provide context for Henderson's admissions).

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