People v. Brand

This case presents question in instant prosecution on charge of home invasion, aggravated domestic battery and possession of stolen motor vehicle involving defendant’s ex-girlfriend as to whether State properly authenticated social media screen shot allegedly sent by defendant to ex-girlfriend. Appellate Court found that State presented sufficient evidence to authenticate instant Facebook message, where: (1) there was testimony from ex-girlfriend that defendant messaged her on Facebook multiple times under “Masetti Meech” username which appeared on subject screen shot; and (2) instant message contained content that was not widely known to persons other than defendant and girlfriend, including location of ex-girlfriend's stolen car. Defendant argued that there was lack of authentication of screen shot, where State failed to produce messages that appeared before and after screen shot. He also argued that record lacked sufficient evidence to support his stolen motor vehicle conviction, where State failed to show that he took vehicle with intention to permanently deprive ex-girlfriend of her vehicle.