In a decision that affirms the admissibility and sufficiency of several distinct types of evidence, the U.S. Court of Appeals for the Eleventh Circuit recently presided over an appeal that found its roots in the U.S. District Court for the Northern District of Alabama. This case, US v Mapson, defines the power of juries to draw inferences from evidence that, when taken together, holistically represents the claim, while simultaneously legitimizing two specific applications of evidence.
Sisters Tierzah, Charis, and Elisa Mapson all faced multiple charges following a shooting incident involving Joshua Thornton, the father of Tierzah’s daughter, and his wife. The district court convicted all three sisters of conspiring to commit these acts under 18 U.S.C. §371, as well as two counts of interstate stalking in violation of 18 U.S.C. §2261A(1)-(2). Tierzah was also convicted on two counts of interstate domestic violence under 18 U.S.C. §2261(a)(1)-(a)(2). As a result of these convictions, the district court sentenced Tierzah to 60 months’ imprisonment. Charis and Elisa were each sentenced to 120 months’ imprisonment.
The Mapson sisters raised several evidentiary issues on appeal. In response to their respective sentences, each sister raised arguments that the evidence was insufficient to support their convictions. Charis and Elisa also raised specific evidentiary challenges, with both sisters arguing against the admission of data obtained by automated license plate readers (ALPRs) was inadmissible. They argued that the use of the ALPR data was a warrantless search in violation of the Fourth Amendment, and that the witness who testified to the data itself was not a qualified expert under Federal Rule of Evidence 702. Charis also raised an additional evidentiary argument specific to her cases, arguing that the district court erred in allowing testimony by her former partner asserting that she had once owned an AR rifle, claiming that the statement was prejudicial hearsay under Federal Rule of Evidence 801(c), and was therefore inadmissible.
The Eleventh Circuit clarified the evidentiary standard, both broadly and in the context of this particular case, on each point. Reviewing the sisters’ arguments in the light most favorable to the jury’s verdicts, the Court found that there were four distinct categories of fact from which the jury could infer motive to conspire. In reaching this conclusion, the Court noted that, in criminal cases, the defendants’ motive is relevant to the sufficiency of the evidence. Taken together, however, the evidence presented was sufficient to infer the elements of conspiracy, including motive, and so the convictions of all three sisters were affirmed. The Court also rejected Charis and Elisa’s specific evidentiary challenges, holding that the ALPR data was admissible because it served as a good-faith exception to the exclusionary rule, and the use of such data did not require expert testimony. Additionally, the Court rejected Charis’s hearsay challenge, noting that an admission by a party opponent is admissible under the Federal Rules of Evidence.
US v. Mapson serves as an illustration of the proper application of federal evidentiary standards in criminal cases. Although the Mapson sisters ultimately lost their appeal, the Eleventh Circuit’s ruling offers key insight into the jury’s power to draw inferences based on a categorically broad array of evidence, while also clarifying the function of Federal Rule of Evidence 702 and 801(c) in criminal trials.