RICKY PAUL PATTERSON, JR.
v.
STATE OF FLORIDA
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Ricky Patterson appeals his conviction for violating a domestic violence protection injunction, challenging the trial court's admission of testimony about phone calls and voicemails from the victim without proper authentication. The appellate court affirmed the conviction, holding that witness testimony about personal knowledge of phone calls does not require separate authentication under Florida law.
The trial court did not abuse its discretion. When a witness testifies to events within her personal knowledge, such testimony is admissible without further authentication. The victim's personal knowledge of receiving a phone call from Patterson's number constituted sufficient authentication of the evidence of contact.
[1] Testimony regarding a phone call is admissible without further authentication when the witness testifies to receiving the call from a number saved in her phone as belongi…
[2] Authentication of evidence is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“authentication or identification of evidence is required as a condition precedent to its admissibility”
Establishes the general rule requiring authentication of evidence under Florida law
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Join FLexlaw to unlock all legal intelligencePatterson was convicted of violating a protection injunction against domestic violence under section 741.31, Florida Statutes. At trial, the victim te…
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LONG, J.
Ricky Patterson appeals his conviction for violation of an injunction for protection against domestic violence in violation of section 741.31, Florida Statutes (2020). The State presented witness testimony that Patterson violated the injunction by contacting the victim via a telephone call and voicemail. Patterson argues that the trial court abused its discretion in admitting the testimony regarding the phone call and voicemail without proper authentication.
While it is true that “authentication or identification of evidence is required as a condition precedent to its admissibility” and that authentication is “satisfied by evidence sufficient to support a finding that the matter in question is what its proponent
claims,” § 90.901, Fla. Stat., when a witness testifies to something within her personal knowledge, that testimony is admissible without further authentication because “[e]vidence to prove personal knowledge may be given by the witness’s own testimony.” Here, the victim testified that she received a phone call from a phone number saved in her phone as Patterson’s. Testifying about a phone call does not require authentication if the call is within the witness’s personal knowledge. The trial court did not abuse its discretion by admitting the victim’s testimony.
AFFIRMED. MAKAR and WINOKUR, JJ., concur. _____________________________