UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
UNITED STATES OF AMERICA,
SANDRA CAMPBELL, et al.,
Case No. 12-20054
Honorable Julian Abele Cook, Jr.
On February 1, 2012, a grand jury returned a nine-count indictment against the Defendants,
Sandra Campbell and Domonique Campbell, both of whom were accused of, inter alia, conspiring
to defraud the Detroit Public School District (“DPS”), conspiracy to launder the proceeds of the
scheme to defraud, and conspiracy to defraud the United States. Sandra Campbell has requested the
admission of a certified copy of a police report which indicates that she reported her laptop stolen.
The Government objects to the admission of the document because it contains hearsay statements.
A police report which contains the observations of the authoring officer is generally
admissible as a business record if offered by the defendant. United States v. Snyder, 787 F.2d 1429,
1434 (10th Cir. 1986) (“[E]ntries in a police or investigating officer’s report which result from the
officer’s own observations and knowledge” are admissible under Rule 803(6) if offered by the
defendant); United States v. Smith, 521 F.2d 957, 964-65 (D.C. Cir. 1975). However, when the
report contains statements of a third-party, those statements are considered hearsay and must meet
a hearsay exception in order to be admitted. Miller v. Field, 35 F.3d 1088, 1091 (6th Cir. 1994).
Here, the report contains out-of-court statements made by Sandra Campbell. Campbell has not
provided an exception to the hearsay rule which would allow the admission of these statements.
Nevertheless, a report that is offered for a non-hearsay purpose may be admissible. In this
case, the police report offered by Sandra Campbell is admissible as evidence that she reported
her laptop stolen but is not admissible as evidence that the laptop was actually stolen. United
States v. Ott, 229 F.3d 1155, at *5 (6th Cir. 2000) (unpublished table decision) (“A police report
detailing the facts of an alleged theft, which is offered only to prove that the theft was reported,
says nothing whatsoever about whether that item was, in fact, actually stolen. Such a report is
not offered to prove the truth of the matter asserted, and is not hearsay at all.”); see also United
States v. Graham, 391 F.2d 439, 448 (6th Cir. 1968) (“Were it relevant, the police record in
evidence would of course be admissible as proof that the car to which it referred had been
IT IS SO ORDERED.
Date: July 31, 2013
s/Julian Abele Cook, Jr.
JULIAN ABELE COOK, JR.
U.S. District Judge
The undersigned certifies that the foregoing Order was served upon counsel of record via the Court's ECF System to their
respective email addresses or First Class U.S. mail to the non-ECF participants on July 31, 2013.
CERTIFICATE OF SERVICE
s/ Kay Doaks