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Authentication — Voice on Tape

State v. Gary Curtis, 218 Wis. 2d 550, 582 N.W.2d 409 (Ct. App. 1998)
For Curtis: Arthur B. Nathan

Issue/Holding:

Next, Curtis claims that the tapes admitted into evidence at trial were not properly authenticated. At trial, Poivey, a party to the conversations on the tapes, testified that the voices on the tapes were his and Curtis’. This type of voice identification is a valid avenue of authentication. See United States v. Carrasco, 887 F.2d 794, 803 (7th Cir. 1989). In Carrasco, a man who bought falsified green cards from the defendant identified the defendant’s voice and his own in the recorded conversations. See id. at 796, 803. The Seventh Circuit held that tapes are properly identified and authenticated when a party to the recorded conversation identifies the defendant’s voice and testifies that the tapes accurately depict the conversations. See id. at 803. We adopt the reasoning of Carrasco and apply it to this case. Poivey’s identification of Curtis’ voice on the tapes was adequate authentication of the tapes.

 

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