State v. DeJesus, ___ N.C. App. ___, 827 S.E.2d 744 (May. 7, 2019)

In this statutory rape case, the court rejected the defendant’s argument that the trial court erred by admitting the victim’s Honduran birth certificate, asserted by the defendant to be inadmissible hearsay. To establish the victim’s age, the State introduced a copy of the victim’s Honduran birth certificate, obtained from her school file. The defendant argued that the document lacked sufficient trustworthiness to satisfy Evidence Rule 803(8) (public records and reports). The court disagreed. No circumstances suggest that the birth date on the certificate lacked trustworthiness. Moreover, there was additional evidence presented supporting the victim’s age, including photographs taken of her, and a detective’s testimony that the victim looked to be 10 or 11 years old at the time of her interview.