Crone, J.
Presley Jermaine Brown appeals his convictions for murder, a felony, and level 3 felony attempted armed robbery. He contends that the trial court erred by admitting documents purportedly handwritten by Brown without authenticating the handwriting as Brown’s. Finding no error in the admission of the documents, we affirm.
Brown challenges the admission of Exhibits 401, 402, and 403, arguing that there was insufficient evidence of authentication.
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Brown objected to the admissibility of Exhibit 401 because there was insufficient evidence that he had written the letter. The trial court took judicial notice that Exhibits 402 and 403 had been written by Brown and admitted them as examples for the jury to determine whether Exhibit 401 had been written Brown. Brown contends that the trial court erred in allowing the jury to determine whether he wrote Exhibit 401 by comparing the handwriting in Exhibit 401 with that in Exhibits 402 and 403 because they had not been properly authenticated.
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[W]e find Owen v. State, 272 Ind. 122, 396 N.E.2d 376 (1979), [ ] helpful. There, Owen was charged with robbery and represented himself pro se. The prosecutor asked the trial court to take judicial notice of Owen’s pleadings and filings in the cause and allow the jury to compare them to a handwritten note left by the robber at the scene of the robbery. Our supreme court concluded that it was reasonable “under the circumstances of this case, for the court to take judicial notice of the fact that the defendant is the one who did, in fact, sign these pleadings.” Id. at 129, 396 N.E.2d at 381. The Owen court reasoned that it was reasonable based on the following circumstances:
[Owen] acted as his own attorney in this cause throughout the pleading stage, tried the case before the jury, argued these matters and spoke of them before the jury during the trial and in final argument. He testified as a witness in his own behalf and never denied that he was the one who actually wrote all of the pleadings and signed his name thereto.
Id., 396 N.E.2d at 381. The Owen court continued, “The trial judge may take judicial notice [that the defendant signed the pleadings], and a rebuttable presumption arises which requires the defendant to come forward with any evidence to dispute the presumption.” Id., 396 N.E.2d at 381 The court noted that Owen did not attempt to demonstrate that the documents judicially noticed were not written by him, but only objected to notice being taken of them because the trial judge did not personally see him sign them. Id., 396 N.E.2d at 382. Accordingly, the Owen court concluded that the “trial court could have taken judicial notice that the documents were in the record filed on behalf of the defendant and have permitted the jury to infer that they were, in fact, signed by the defendant.” Id. at 130, 396 N.E.2d at 382.
Although Brown did not proceed pro se as Owen did, we have no difficulty concluding that under the circumstances it was reasonable for the trial court to take judicial notice that the handwriting and signatures in Exhibits 402 and 403 were Brown’s. We first examine Exhibit 403, the 2018 letter to the trial court complaining about the lack of communication from Brown’s court-appointed attorney. The contents of the letter, that it was mailed from the jail where Brown was incarcerated, that a hearing was held to address the letter’s concerns, that Brown appeared at the hearing, and that the concerns expressed in the letter were resolved and a pretrial hearing was set all support the trial court’s decision to take judicial notice that the handwriting and signature in Exhibit 403 were Brown’s. Exhibit 402, the 2019 letter from Brown, was mailed from the jail where Brown was incarcerated and asked the clerk to send Brown the CCS, and the handwriting looks like the handwriting in the 2018 letter. Under the circumstances, it was reasonable for the trial court to take judicial notice that the documents filed with the court had been written by Brown. Therefore, the trial court did not abuse its discretion in admitting the State’s exhibits, and we affirm Brown’s convictions.
Affirmed.
Bailey, J., and Altice, J., concur.