New Mexico Supreme Court
State v. Jesenya O.
June 16, 2022514 P.3d 445
Summary
The New Mexico Supreme Court held that social-media evidence is authenticated under the traditional standard in Rule 11-901, rather than a heightened standard directed specifically at social-media communications. It further held that the State presented sufficient circumstantial evidence to authenticate Facebook Messenger screenshots allegedly sent by the child and that the district court did not abuse its discretion by admitting them. The court therefore reversed the Court of Appeals and reinstated the delinquency adjudications.
Holding
- Authentication standard for social-media evidence. The traditional authentication standard in Rule 11-901 governs social-media evidence; a heightened, social-media-specific authentication standard is not required.
- Authentication of the February 25 Facebook Messenger screenshots. The screenshots were sufficiently authenticated because the account's identifying information, Erickson's personal knowledge and history of communicating with Jesenya, and the messages' content together supported a finding that the messages were more likely than not what the State claimed them to be. The district court therefore did not abuse its discretion by admitting them.
Docket S-1-SC-38769
Cited authorities
- Fed. R. Evid. 901