## Facts

- Angela L. Jackson, a law student, bought approximately $2,000 of African-American art prints to resell and arranged shipment to her Minnesota address using four pre-addressed UPS mailers marked “Kwanzaa.”
- UPS delivered four packages to Jackson’s apartment building; a UPS driver, receptionist, and concierge testified all four were delivered and none were damaged or defaced when received.
- Jackson told UPS she received only three packages and that all were damaged and contained racial epithets.
- Jackson submitted a UPS claim for $572,000, despite the relatively low purchase price, lack of sales orders, and evidence the artist’s prints typically sold for modest amounts.
- After UPS resisted paying the claim, Jackson sent communications accusing UPS of racism and generated “hate packages” and related materials aimed at supporting her account and shifting blame to others.
- Evidence linked Jackson to the hate-mail activity and cover-up efforts, including online research into white-supremacist groups, fabricated emails, and an attempt to create a false alibi using medical records.
- At trial, Jackson sought to introduce printouts of alleged white-supremacist website postings claiming responsibility for the hate packages, but offered no proof tying the postings to the purported authors.
- The district court excluded the website printouts for lack of authentication, and a jury convicted Jackson on all counts.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Evidence 901 by excluding printouts of purported website postings offered to show third-party responsibility for the hate packages.
2. Whether the evidence was sufficient to support Jackson’s fraud convictions based on her UPS damage-and-value claim and related conduct.

## Decision

- The Seventh Circuit affirmed the convictions.
- The court held the district court did not abuse its discretion in excluding the website postings because Jackson failed to authenticate them under Rule 901.
- The court held the evidence was sufficient for a rational jury to find Jackson engaged in a scheme to defraud UPS, with the hate-mail activity serving as circumstantial proof of intent and consciousness of guilt rather than the core of the charged fraud.

## Legal Principles

- Under Federal Rule of Evidence 901(a), the proponent must present evidence sufficient to support a finding that an item is what the proponent claims it is.
- Internet printouts are not self-authenticating; admission generally requires testimony, technical proof, or other reliable circumstantial evidence connecting the material to its purported source and showing it is genuine.
- A trial court’s authentication ruling is reviewed for abuse of discretion, and exclusion is proper when the proponent offers no competent link between the printout and the claimed author.
- On sufficiency review, the evidence is viewed in the light most favorable to the prosecution, and a conviction stands if a rational jury could find the elements proved beyond a reasonable doubt.
- Post-claim conduct designed to bolster a false narrative or conceal responsibility may be used as circumstantial evidence of fraudulent intent.

## Conclusion

The Seventh Circuit affirmed Jackson’s fraud convictions arising from an inflated UPS claim and upheld exclusion of purported website postings because she failed to authenticate the printouts as genuine statements of the organizations she attributed them to under Federal Rule of Evidence 901.


United States v. Jackson, 208 F.3d 633 (7th Cir. 2000)