People v. Brand

Defendant was convicted, after bench trial, of aggravated domestic battery, home invasion, and possession of a stolen or converted motor vehicle. Court did not abuse its discretion by admitting evidence as to contents of messages allegedly sent by Defendant to victim via Facebook Messenger. State presented sufficient circumstantial evidence properly authenticating the 2 Facebook Messenger messages; the victim testified that while she and Defendant were dating, Defendant messaged her via Facebook messenger multiple times under the same username.. State provided evidence that both messages contained unique information not widely known to persons other than Defendant and victim.   State proved Defendant guilty beyond a reasonable doubt of possession of a stolen or converted motor vehicle. State was only required to prove that Defendant knew the car was either stolen or converted, and evidence proved that Defendant knew he either stole the vehicle or converted it, and that he knowingly and wrongfully deprived victim of her vehicle for several days. (A. BURKE, GARMAN, THEIS, NEVILLE, M. BURKE, and OVERSTREET, concurring.)