## Facts

- Cecil W. Chandler III was prosecuted in federal court for participating in a cocaine-distribution conspiracy.
- At trial, the government sought to introduce a photograph of Chandler taken while he was serving a prior prison sentence.
- The photograph was found in a letter Chandler sent to his girlfriend, Natasha Moore.
- Investigators discovered the letter containing the photograph among other letters from Chandler to Moore at Moore’s home.
- The photo showed Chandler surrounded by six other prisoners; one of the men in the photo was Ron Espy, described at trial as a known drug convict.
- A handwritten caption appeared on the photograph stating: “I keep a Firm no matter where I’m at, baby.”
- The government presented testimony from three witnesses that Chandler referred to his drug organization as “The Firm.”
- Chandler objected to admission of the photograph and caption, arguing that the handwritten caption was not properly authenticated as his writing.
- The district court overruled the objection and admitted the photograph with the caption.
- Chandler was convicted and appealed, challenging the admission of the captioned photograph on authentication grounds.

## Issues

1. Whether the district court abused its discretion by admitting the photograph with the handwritten caption when Chandler argued the caption was not properly authenticated under Federal Rule of Evidence 901.

## Decision

- The Tenth Circuit affirmed.
- The court held that the district court did not abuse its discretion in admitting the photograph and caption because there was enough evidence for a reasonable juror to find the caption was what the government claimed it to be.
- The court relied on the circumstances connecting the photograph to Chandler (its inclusion in his letter to Moore and its discovery with other Chandler letters) and the trial evidence linking Chandler to the term “The Firm.”

## Legal Principles

- Under Federal Rule of Evidence 901(a), the proponent must produce evidence sufficient to support a finding that the item is what the proponent claims it is.
- Authentication can be established through circumstantial evidence, including an item’s contents, distinctive characteristics, and the context in which it was found.
- A trial court’s Rule 901 authentication ruling is reviewed for abuse of discretion.
- At the authentication stage, the court determines only whether a reasonable juror could find the evidence genuine; disputes about authorship generally go to weight, not admissibility.

## Conclusion

In *United States v. Chandler*, the Tenth Circuit upheld Chandler’s conviction, concluding that the district court acted within its discretion in admitting a prison photograph bearing the caption “I keep a Firm no matter where I’m at, baby,” because the surrounding circumstances and supporting testimony provided sufficient evidence of authenticity under Rule 901.


United States v. Chandler, 5 Fed. App’x 839 (2001)