Commonwealth v. Williams
- Court
- Massachusetts Supreme Judicial Court (State high court)
- Decided
- 2010
- Citation
- 456 Mass. 857 (2010)
- Standard applied
- Authentication of platform messages — access versus authorship
What the court held
There was insufficient evidence to authenticate MySpace messages urging a witness not to testify, and they should not have been admitted. Testimony that the messages arrived from an account bearing the sender's name and photograph established only that someone with access to that page sent them, not who sent them. The error did not create a substantial likelihood of a miscarriage of justice, so the conviction stood.
Why
The court noted the absence of any testimony about how secure such a page is, who can access it, or whether codes are needed, and no expert evidence that no one other than the account holder could send from it. Analogising to telephone calls, it held that a recipient's testimony that the caller claimed to be a particular person is not enough on its own to admit the call as that person's.
Our reading — not the court’s words
Why this matters in practice
Williams identifies precisely the evidence that would have cured the problem, and it is evidence a forensic examiner produces: account security, who could log in, and whether the platform's records show the session. It is the clearest judicial statement that access and authorship are different findings. Note also the harmless-error outcome — winning the authentication point frequently does not win the appeal, which is why the objection is worth far more at trial than afterwards.
This paragraph is Legal Cyber Academy’s editorial assessment of the decision’s practical importance. The court said none of it. For what the court actually said, read the opinion.
Additional detail
Tags: MySpace · authorship · account security · harmless error
Cited 48times in CourtListener’s corpus at the time this entry was compiled. Treat it as a rough measure of influence, not of correctness.
Other decisions on authentication
- Tienda v. StateCourt of Criminal Appeals of Texas · 2012The court affirmed the admission of printouts from MySpace profiles attributed to the defendant, holding that the internal content of the pages — photographs, r…
- People v. GoldsmithCalifornia Supreme Court · 2014Photographs and video from an automated traffic-enforcement system were adequately authenticated by the testimony of an investigating officer, and were not hear…
- United States v. HassanCourt of Appeals for the Fourth Circuit · 2014Screenshots of Facebook pages and YouTube videos were self-authenticating as business records under Rule 902(11), supported by certifications from the platforms…
- Lorraine v. Markel American Insurance Co.District Court, D. Maryland · 2007Neither party's electronic exhibits could be considered because none was authenticated: e-mails were simply attached to the motions rather than supported by aff…
- United States v. VaynerCourt of Appeals for the Second Circuit · 2014A printout of a profile page from a Russian social-networking site was admitted without adequate authentication under Rule 901, because the government offered n…
- Commonwealth v. PurdyMassachusetts Supreme Judicial Court · 2011E-mail exchanges recovered from a computer the defendant admitted owning, and for which he supplied all the passwords, were sufficiently authenticated as his, a…
Summarised from the opinion as retrieved from CourtListener. Reference material, not legal advice. Back to the repository.