Tyrone C. Jackson v. United States

STEADMAN, Senior Judge:

A T-Mobile Google cell phone with a dead battery was introduced into evidence at the joint trial of appellant Tyrone C. Jackson and his co-defendant, Alex Dickens, its owner. The cell phone was given to the jury along with other evidence to have during deliberations. On its own, the jury managed to activate the cell phone and peruse its contents. After inquiry, the court denied appellant’s motion for a mistrial and instead gave a limiting instruction. The issue on appeal is whether, in so doing, the court abused its discretion. We hold that it did not and affirm…