People v. Smith

Summary

The court held that cell-phone recordings of selected portions of surveillance footage were duplicates admissible under Illinois Rule of Evidence 1003 because the rule does not require a duplicate to reproduce the entire original. Admission was not unfair where the recordings were accurate, the defense could expose the missing footage and challenge its significance, and the jury heard evidence addressing the surrounding circumstances. The court also held that Illinois's codified evidence rules abrogated the common-law best evidence rule and declined to remand for consideration of a separate foundation challenge that defendant had not pursued as an appellate issue.