Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
State v. Harris, ___ N.C. App. ___, 800 S.E.2d 676 (May. 2, 2017)
The trial court did not err by allowing the introduction of a video recording of the State’s witness being interviewed by law enforcement as substantive evidence where the statement fell within the Rule 803(5) hearsay exception for past recollection recorded. The court rejected the notion that the video had been introduced to refresh the witness’s recollection.