Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Buie, 194 N.C. App. 725 (Jan. 6, 2009)
The trial judge erred in allowing a detective to offer lay opinion testimony regarding whether what was depicted in crime scene surveillance videos was consistent with the victim’s testimony. For example, the detective was impermissibly allowed to testify that the videotapes showed a car door being opened, a car door being closed, and a vehicle driving away. The court found that the officer’s testimony was neither a shorthand statement of facts nor based on firsthand knowledge.