Admission of Immigration Files Held to Be Non-Testimonial; Crawford Claim Rebuffed

U.S. v. Lara-Ibanez, 2006 WL 3086699 (11/1/06)(unpub'd) - The 10th holds that the admission of the defendant's immigration files, including the deportation warrant, and a certificate of non-existence of a record, did not violate Crawford because that evidence is non-testimonial and admissible under the public records hearsay exceptions---Fed. R. Evid 803(8) & (10).