## Facts

- Columbus Schalah Stephens, Jr. obtained federally related loans connected to cattle operations financed by the Farmers Home Administration (FmHA).
- The government alleged Stephens made materially false statements and misrepresentations to FmHA, including overvaluing collateral and misstating livestock inventory and financial condition to obtain or maintain credit.
- The prosecution’s proof relied on numerous, complex documentary exhibits concerning loan transactions and related records.
- To organize the voluminous evidence, the government offered summary charts that grouped the underlying exhibits into categories; the district court instructed the jury that the charts were summaries and that the underlying evidence controlled.
- A jury in the Northern District of Texas convicted Stephens on multiple counts for making false statements to a federal agency in violation of 18 U.S.C. § 1001 and related provisions.

## Issues

1. Whether the district court erred by admitting government summary charts as evidence under Federal Rule of Evidence 1006.
2. Whether the charts’ organization and labeling made them impermissibly argumentative and unfairly prejudicial.
3. Whether the evidence, viewed most favorably to the verdict, was sufficient to prove Stephens knowingly made material false statements to FmHA with intent to defraud.

## Decision

- The Fifth Circuit affirmed the convictions.
- The court held the summary charts were admissible under Rule 1006 because they summarized voluminous admissible records made available to the defense and were used with appropriate limiting instructions.
- The court rejected the claim that the charts were impermissibly argumentative, concluding any risk of prejudice was mitigated by instructions and cross-examination, and the charts helped the jury manage complex records.
- The court held the evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that Stephens made knowing, material false statements with fraudulent intent.

## Legal Principles

- Under Federal Rule of Evidence 1006, summaries may be admitted to prove the content of voluminous writings that cannot be conveniently examined in court, provided the underlying materials are admissible, available to the opposing party, and the summary fairly represents the source data.
- Trial courts have discretion to permit summary charts to assist the jury in organizing complex documentary proof; limiting instructions and opportunity for cross-examination reduce the risk of unfair prejudice.
- On appellate review of sufficiency of the evidence, the court views the evidence in the light most favorable to the government, resolves conflicts in the government’s favor, and grants reasonable inferences supporting the verdict; the question is whether a reasonable trier of fact could find guilt beyond a reasonable doubt.

## Conclusion

The Fifth Circuit affirmed Stephens’s false-statement convictions, holding that Rule 1006 permitted admission of government summary charts summarizing voluminous loan records and that the trial evidence allowed a reasonable jury to find knowing, material misrepresentations to FmHA made with intent to defraud.


United States v. Stephens, 779 F.2d 232 (5th Cir. 1985)