The 2nd U.S. Circuit Court of Appeals has set the standard for the admission of lay witness testimony to authenticate handwriting.

The circuit said that two rules of evidence must be applied to allow lay testimony into evidence in United States v. Samet, 03-1420, and it upheld the evidence offered by a U.S. postal inspector against one of the defendants in a massive fraud out of the Kiryas Joel community in Monroe, N.Y.