By: Derek Hawkins//May 16, 2016//
7th Circuit Court of Appeals
Case Name: United States v. Jerry Brown
Case No.: 14-1363; 14-1364;14-1426; 14-2689
Officials: Chief Judge, ROVNER, Circuit Judge, and SHAH, District Judge. *
Focus: General Appeal – Abuse of Discretion
Use of Western Union Records to evidence drug trafficking transactions admissible. Court did not abuse discretion in admitting records into evidence.
“The First and Tenth Circuits have directly addressed West‐ ern Union records. The Tenth Circuit found Western Union records inadmissible to prove the identity of the senders of money, because no identification was required to send money, but the records could be used to prove the identity of recipients because identification was required to receive the money. United States v. McIntyre, 997 F.2d 687, 701–02 (10th Cir. 1993). The First Circuit similarly concluded that Western Union records provided by the company could not be admitted to prove the identity and address of the sender. United States v. Vigneau, 187 F.3d 70, 77 (1st Cir. 1999). “
Affirmed