## Facts

- Nathan Cornell was assaulted at a graduation party and suffered serious facial injuries and lost teeth.
- Cornell told police he was struck from behind, knocked down, and repeatedly kicked and punched by Tyler Kristian Mangel and Matthew Robert Craft.
- Cornell reported he did not know either defendant and identified them after family showed him Facebook photos.
- The Commonwealth charged both defendants with aggravated assault, simple assault, and harassment; the cases were consolidated for trial.
- Before trial, the Commonwealth sought to introduce screenshots of undated Facebook chat messages from an account named “Tyler Mangel” and a screenshot depicting purportedly bloody hands posted by another Facebook account.
- The “Tyler Mangel” account listed identifying profile details (including hometown and high school) and contained photos appearing to depict Mangel.
- A computer-forensics detective testified about investigating the account but could not conclusively link Mangel to control of the account or to authorship of the specific messages.
- The trial court denied the Commonwealth’s motion in limine and excluded the Facebook evidence for lack of authentication.

## Issues

1. Whether the trial court abused its discretion or applied an incorrect legal standard by excluding Facebook posts and messages because the Commonwealth failed to authenticate them as authored by Mangel under Pennsylvania Rule of Evidence 901.

## Decision

- The Superior Court of Pennsylvania affirmed the exclusion order.
- The court held the Commonwealth’s showing—screenshots from an account bearing Mangel’s name and biographical details plus photos resembling him—did not sufficiently authenticate that Mangel authored the specific messages and posts.
- The court concluded the trial court did not abuse its discretion in determining Rule 901 was not satisfied.

## Legal Principles

- Under Pa.R.E. 901(a), the proponent must produce evidence sufficient to support a finding that the item is what the proponent claims it is.
- For social-media communications, a message cannot be attributed to a person merely because it came from an account bearing that person’s name or containing that person’s photos.
- Because third parties may create, access, or use an account, authentication generally requires additional direct or circumstantial evidence linking the purported author to the particular communication (e.g., witness testimony with personal knowledge, corroborating context, admissions, or technical/forensic linkage).
- Appellate review of authentication and evidentiary admissibility rulings is for abuse of discretion.

## Conclusion

The Superior Court upheld the trial court’s refusal to admit Facebook screenshots because the Commonwealth did not provide sufficient evidence—beyond profile identifiers and screenshots—to support a finding that Mangel authored the specific posts and messages, as required by Pa.R.E. 901.


Commonwealth v. Mangel, 181 A.3d 1154 (Pa. Super. Ct. 2018)