A document was authentic when:
- Applying Tex. R. Evid. 901(b)(4): “Fleming produced uncertified copies of the Harpst jury verdict and final judgment, which the trial court judge had himself received and signed in the Harpst plaintiffs’ case. The documents bore a diagonal watermark from the district clerk’s office, a stamp and signature noting when they were filed in the clerk’s office, and the trial judge’s own signature. The Wilson plaintiffs never suggested that the documents were faked, forged, or altered, but instead complained only that they were not certified copies.”
- Applying Tex. R. Evid. 901(b)(7): “While a certified copy of a public record would automatically be self-authenticating, Tex. R. Evid. 902[b](4), an uncertified copy of a public record could itself contain sufficient evidence that it was filed or kept in a public office. See Tex. R. Evid. 901(a). Here, the watermark and file stamp from the district clerk’s office on the documents qualify as sufficient evidence, so the trial court did not abuse its discretion by finding them authentic.”
Fleming v. Wilson, No. 19-0230 (Oct. 9, 2020) (per curiam).