## Facts

- Nick Cloyd Enterline operated a vehicle salvage business from a lot in Fayetteville, Arkansas, and lived in a building on the lot.
- The government alleged Enterline used the salvage business to run a “changeover” scheme: he obtained a wrecked or salvaged vehicle, arranged for a matching vehicle (same year, make, and model) to be stolen, transferred the salvaged vehicle’s vehicle identification number (VIN) to the stolen vehicle, and then registered the stolen vehicle under the salvaged vehicle’s identity.
- A federal grand jury indicted Enterline on five counts tied to specific vehicles, including two counts of transporting stolen vehicles in interstate commerce (18 U.S.C. §§ 2312, 2(b)) and two counts of possessing vehicles with removed or altered VINs with intent to sell (18 U.S.C. § 2321), plus an additional stolen-vehicle possession count (18 U.S.C. § 2313).
- At trial, the government presented testimony from more than twenty-five witnesses. Four convicted car thieves testified that they stole the charged vehicles at Enterline’s request.
- Law-enforcement officers seized records from Enterline’s home that contained VINs connected to the scheme.
- FBI Special Agent Edward Satterfield entered the seized VINs into a computer system and generated a computer report indicating whether the VINs had been reported stolen.
- The computer report itself was not received as an exhibit; instead, Satterfield testified about what the report showed (that several vehicles were reported stolen).
- Enterline denied ordering thefts and maintained the transactions were legitimate salvage-business purchases and sales.
- The jury convicted Enterline on four counts and acquitted him on one count. The district court sentenced him to fifteen years’ imprisonment.
- On appeal, Enterline argued, among other claims, that Satterfield’s testimony based on the computer report was inadmissible hearsay.

## Issues

1. Whether the district court erred by admitting an FBI agent’s testimony, based on a computer-generated VIN report, that certain vehicles were reported stolen—either because it was hearsay or because it fell within the criminal-case limitation in Fed. R. Evid. 803(8) for matters observed by law-enforcement personnel.

## Decision

- The Eighth Circuit affirmed Enterline’s convictions and sentence.
- The court held that the challenged testimony was properly admitted under Fed. R. Evid. 803(8) because the computer-reported stolen-vehicle status reflected routine, objective recordkeeping rather than investigative observations barred in criminal cases.
- The court rejected the claim that Rule 803(8)’s law-enforcement limitation required exclusion, reasoning that the relevant content was the mechanical recording/compilation of an unambiguous factual matter (reported stolen status), not an officer’s evaluative account from an investigation.

## Legal Principles

- Under Fed. R. Evid. 803(8), certain public records and data compilations are admissible as an exception to hearsay when they set out agency activities or matters recorded under a duty to report, provided the source and circumstances do not show a lack of trustworthiness.
- In criminal cases, Rule 803(8)’s limitation for “matters observed by police officers and other law enforcement personnel” targets investigative observations prepared for prosecution, not routine and non-evaluative recording of objective facts.
- A computer-generated report reflecting an agency database entry that a VIN has been reported stolen may qualify as a public-record data compilation when the entry involves mechanical recording of a straightforward fact, rather than conclusions about a defendant’s conduct.
- Testimony describing the contents of such a routine government data compilation may be admitted when it is offered to prove the recorded status information (e.g., that a VIN is listed as reported stolen) and the recordkeeping is not shown to be unreliable.

## Conclusion

United States v. Enterline held that the district court did not commit evidentiary error by allowing an FBI agent to testify, based on a computer-generated VIN report, that certain vehicles connected to Enterline’s changeover scheme had been reported stolen; the Eighth Circuit treated the stolen-status information as routine public-record data within Rule 803(8), affirmed the jury’s four-count conviction, and left the fifteen-year sentence in place.


United States v. Enterline, 894 F.2d 287 (1990)