How have courts treated the issue of identification of a voice on a ransom tape?

To resolve this claim, we must first decide whether the analogy drawn by appellant is a valid one. We have not, in the past, been receptive to this line of reasoning. In United States v. Albergo, 539 F.2d 860, 864 (2d Cir.), cert. denied, 429 U.S. 1000, 97 S.Ct. 529, 50 L.Ed.2d 611 (1976), we stated that "the requirements for voice authentication do not differ markedly from those for document authentication. Once a prima facie case of authorship is made out by the proponent of the evidence, the testimony is admissible; and the reliability ... is for the jury." ⁵ We did, however, go on to leave open the possibility that "there might be some conceivable circumstances in which appellant's due process contentions would have merit...." Id. Moreover, in United States v. Moore, 571 F.2d 76, 90-91 (2d Cir. 1978), we applied due process standards to identification of a voice on a ransom tape, albeit without discussion of Albergo.