USA v. Johnson

2:24-cr-00221LaedNov 7, 2025

Full text

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA 	CRIMINAL ACTION
VERSUS 	No. 24-221
AARON TEROD JOHNSON 	SECTION I
ORDER
Before the Court is the government’s motion1 in limine seeking a preliminary
determination of the admissibility of evidence pursuant to the business records
exception to the hearsay rule, Rule 803(6), and recognition that the birth certificates
of the two minor victims are self-authenticating records pursuant to Federal Rule of
Evidence 902. Defendant Aaron Terod Johnson (“Johnson”) filed a response2 in
opposition. For the foregoing reasons, the Court GRANTS the government’s motion.
I. 	BACKGROUND
As is relevant to this motion, Johnson is charged with three counts: sex
trafficking of a minor, in violation of 18 U.S.C. §§ 1591(a)(1) and 1591(b)(2) (Count
1); coercion and enticement of a minor to engage in sexual activity, in violation of 18
U.S.C. § 2422(b) (Count 2); and interstate transportation of a minor for criminal
sexual activity, in violation of 18 U.S.C. § 2423(a) (Count 3).3 All three counts involve
the same minor victim (“Minor Victim”),4 and one of the birth certificates that the
1 R. Doc. No. 88.
2 R. Doc. No. 106.
3 See generally R. Doc. No. 51.
4 See id.
Case 2:24-cr-00221-LMA-KWR Document 141 Filed 11/07/25 Page 1 of 4
2
government seeks recognition of belongs to Minor Victim.5 The other birth certificate
belongs to a minor victim who is the subject of evidence that the government intends
to introduce at trial pursuant to Federal Rule of Evidence 404(b) (“Minor Victim 2”).6
On October 8, 2025, after the government filed the present motion in limine,
Johnson agreed to stipulate to the authenticity of all the requested business records,
“retaining his rights to challenge the admissibility of the items on any other
permissible grounds.”7 However, Johnson refused to stipulate with respect to the
authenticity of the minor victims’ birth certificates.8 He explains that because the
birth 	certificates 	“would 	prove 	an 	element 	of 	the 	crimes 	with 	which 	he 	is
charged. . . . he cannot offer any stipulations relative to those items.”9 Accordingly,
the only remaining issue before the Court with respect to this motion in limine is
whether the minor victims’ birth certificates qualify as self-authenticating records.
II. 	LEGAL STANDARDS
Pursuant to Federal Rule of Evidence 902, certain “items of evidence are self-
authenticating,” meaning, “they require no extrinsic evidence of authenticity in order
to be admitted.” F ED. R. EVID. 902. One such type of self-authenticating evidence
includes “Domestic Public Documents That Are Sealed and Signed.” F ED. R. EVID.
902(1). Such documents are ones that bear:
(A) a seal purporting to be that of the United States; any state, district,
commonwealth, territory, or insular possession of the United States;
5 See R. Doc. No. 88-1, at 7–8.
6 See id.; see also R. Doc. No. 72, at 1.
7 See R. Doc. No. 106, at 1.
8 See id.
9 See id. at 2.
Case 2:24-cr-00221-LMA-KWR Document 141 Filed 11/07/25 Page 2 of 4
3
the former Panama Canal Zone; the Trust Territory of the Pacific
Islands; 	a 	political 	subdivision 	of 	any 	of 	these 	entities; 	or 	a
department, agency, or officer of any entity named above; and
(B) a signature purporting to be an execution or attestation.
F ED. R. EVID. 902(1).
III. 	ANALYSIS
In its motion, the government explains that it intends to admit the birth
certificates of Minor Victim and Minor Victim 2 without the testimony of a custodian
of record from the Louisiana Department of Health and Hospitals.10 The government
represents that both birth certificates were produced to defense counsel.11 The
government also states that both documents were “provided to the Government by
the Louisiana Department of Health and contain both a raised seal of a department
of 	the 	State 	of 	Louisiana 	and a 	‘signature 	purporting 	to 	be 	an 	execution 	or
attestation.’”12 Johnson does not contest any of these representations made by the
government.13
Because the documents conform to the requirements of Rule 902(1), the Court
finds that, pursuant to Rule 902, the signed and sealed birth certificates are self-
authenticating and require no extrinsic evidence of authenticity for admission. See
United States v. Jones, No. 15-174, 2016 WL 10704381 (E.D. La. Feb. 17, 2016)
(Feldman, J.) (finding that the birth certificates of two minor victims were self-
authenticating in a sex trafficking of a minor case because “[t]he United States
10 See R. Doc. No. 88-1, at 7.
11 See id.
12 See id. (quoting F ED. R. EVID. 902(1)(B)).
13 See generally R. Doc. No. 106.
Case 2:24-cr-00221-LMA-KWR Document 141 Filed 11/07/25 Page 3 of 4
4
submit[ed] that both birth certificates were produced to defense counsel in redacted
form, were provided to the government by the respective governmental entities, and
contain a seal of a department of the respective department of State and a ‘signature
purporting to be an execution or attestation’”).
IV. 	CONCLUSION
Accordingly,
IT IS ORDERED that the government’s motion14 in limine is GRANTED.
The Court hereby recognizes that the two birth certificates of the minor victims are
self-authenticating.
New Orleans, Louisiana, November 7, 2025.
_______________________________________
LANCE M. AFRICK
UNITED STATES DISTRICT JUDGE
14 R. Doc. No. 88.
Case 2:24-cr-00221-LMA-KWR Document 141 Filed 11/07/25 Page 4 of 4

Continue your research in ChatGPT or Claude

Connect Omnilex to search the legal corpus from your AI assistant.