State v. Hon. steinle/alejandra Moran

Summary

The court held that the trial court improperly excluded a thirty-one-second cell-phone video excerpt under the rules governing completeness, best evidence, hearsay, and authentication. Those rules did not independently bar admission because the excerpt could be used to illustrate witness testimony, depicted nonassertive conduct, and could be authenticated through testimony even without a complete chain of custody. The court vacated the lower courts' rulings and remanded for the trial court to decide in the first instance whether Rule 403 requires exclusion.