2:24-cr-00221•USA v. Johnson
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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
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