United States v. Joseph Davis

NIEMEYER, Circuit Judge:

Challenging his conviction for distribution of over 50 grams of methamphetamine, in violation of 21 U.S.C. §§ 841 (a)(1) and 841(b)(1)(A), Joseph Davis contends that the district court erred (1) in admitting an out-of-court statement that a confidential informant made about having purchased drugs from Davis prior to the relevant investigation; (2) in failing to require adequate authentication of an officer's photographs of the informant's cellphone screen as she purportedly texted Davis in preparation for a controlled buy; and (3) in admitting a recording of a…