## Facts

- Mack Pressley, a Philadelphia Inquirer employee, used a 1990 Chevrolet Lumina minivan for newspaper delivery in Philadelphia.
- Pressley was held at gunpoint by two assailants who stole the minivan.
- Later that day, a police officer stopped the stolen minivan and arrested Nafis Woods; the officer recorded the vehicle identification number (VIN).
- To prove the 18 U.S.C. § 2119 interstate-commerce element, the government called FBI Special Agent Jay Heine, who had experience investigating property transported in interstate commerce.
- Heine testified that he used a National Insurance Crime Bureau (NICB) VIN database to trace the VIN to a manufacturing plant in Tarrytown, New York.
- Heine’s VIN-trace testimony was the government’s only evidence that the vehicle had been transported in interstate commerce.
- Woods objected that Heine’s testimony about what the NICB database showed was inadmissible hearsay; the district court overruled the objection, and Woods was convicted.

## Issues

1. Whether an agent’s testimony repeating the contents of an NICB VIN database as to a vehicle’s place of manufacture is inadmissible hearsay.
2. Whether the NICB VIN database qualifies as a “market quotation[], tabulation[], list[], directory[], or other published compilation[]” admissible under Federal Rule of Evidence 803(17).
3. Whether such evidence, if admissible, is sufficient to establish the interstate-commerce element of federal carjacking under 18 U.S.C. § 2119.

## Decision

- The Third Circuit affirmed the conviction.
- The court held that the NICB VIN database fell within Rule 803(17) as a tabulation/directory generally used and relied on by persons in relevant occupations.
- The court concluded that Heine’s testimony based on the database was properly admitted and was sufficient to prove the interstate-commerce element because the minivan was manufactured in New York and recovered in Pennsylvania.

## Legal Principles

- Under Federal Rule of Evidence 803(17), certain published compilations (including tabulations, lists, and directories) are admissible despite hearsay when they are generally used and relied upon by the public or by persons in particular occupations.
- The Rule 803(17) foundation focuses on professional or public reliance on the compilation, not on calling the compilation’s creator or providing extensive proof of how the compilation was assembled.
- A professional reference database mapping VINs to manufacturing locations can qualify as a Rule 803(17) compilation when shown to be routinely used in law-enforcement and related professional work.
- For 18 U.S.C. § 2119, evidence that a vehicle was manufactured in one state and found in another can support a finding that it was transported, shipped, or received in interstate commerce.

## Conclusion

The Third Circuit upheld the admission of VIN-origin testimony derived from an NICB database under Rule 803(17) and affirmed the carjacking conviction because that evidence adequately established the statute’s interstate-commerce requirement.


United States v. Woods, 321 F.3d 361 (3d Cir. 2003)