Hartsfield v. Commonwealth: No “Human Lie Detector” Opinions on Body‑Camera Recordings

I. Introduction

In Tyrone Antoinne Hartsfield v. Commonwealth of Kentucky, the Supreme Court of Kentucky addressed a question that will recur frequently in the era of ubiquitous police body‑worn cameras:

• May a jury hear a police officer, captured on body‑camera, express his personal opinion that the alleged victim is not telling the truth?
• And, if any part of a body‑cam video is offered, must the entire video be admitted “for context”?

The Fayette Circuit Court had answered both questions in favor of admission, denying the Commonwealth’s motion in limine to exclude the officer’s recorded opinion on the complaining witness’s veracity and ruling that if any part of the body‑cam video came in, the whole video would come in. The Court of Appeals reversed, and the Supreme Court—per Justice Thompson—affirmed that reversal.

The opinion squarely holds:

• Police officers’ recorded opinions about a victim’s or witness’s truthfulness are inadmissible, just as such opinions would be inadmissible if given live at trial.
• Lanham v. Commonwealth, which allowed certain accusatory officer statements on interrogation recordings to be played for “context,” is strictly limited to that interrogation setting and does not authorize admission of testimonial credibility opinions on body‑cam footage.
• There is no freestanding “context” or “investigative hearsay” exception to the hearsay rule, and there is no special “body‑cam exception” to the Kentucky Rules of Evidence.
• Trial courts should generally review body‑cam footage in camera and admit only those portions that are independently admissible under the usual evidentiary rules, rather than ordering wholesale admission.

The decision clarifies and tightens Kentucky law at the intersection of credibility evidence, hearsay, and modern video technology, particularly in “word‑against‑word” prosecutions such as rape and assault cases.

II. Summary of the Opinion

A. Factual Background

During the COVID‑19 pandemic, Hartsfield met B.B. online. On September 6, 2020, they met at a Ramada Inn in Lexington and went to B.B.’s room. Later that night, B.B. called 911, reporting that Hartsfield had raped and assaulted her—slapping her, strangling her, threatening to kill her, and forcing oral and vaginal sex.

Police responded. Officers interviewed both B.B. and Hartsfield at the hotel; those interactions were recorded on officers’ body‑worn cameras. B.B. had a mark on her neck. One officer questioned whether it was evidence of strangulation or merely a “hickey.” B.B. agreed to a hospital exam, including a SANE exam and strangulation assessment. Hartsfield admitted sexual contact but claimed it was consensual.

A grand jury indicted Hartsfield on multiple charges: first‑degree rape, first‑degree sodomy, first‑degree strangulation, fourth‑degree assault, terroristic threatening, and first‑degree persistent felony offender (PFO‑1).

B. The Motion in Limine and Trial Court Ruling

Before trial, the Commonwealth filed a motion in limine seeking to exclude what it described as “witnesses’ opinions about the truth of the testimony of another witness, specifically opinions of Lexington Police Officers heard in the Body Worn Camera.” The focus was a portion of an officer’s body‑cam recording in which he expressed disbelief about B.B.’s account.

Key points at the trial level:

• The Commonwealth argued that the officer’s comments about whether he believed B.B. were inadmissible hearsay and improper character/credibility opinions.
• The defense argued those comments were admissible as a lay opinion under KRE 701, rationally based on the officer’s perceptions and helpful to the jury in deciding what actually happened.
• Both parties relied on Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005), but drew opposite lessons from it.
• The trial court, without viewing the video, denied the motion in limine, reasoning that:
  • the body‑cam was the “best evidence” of what happened,
  • any party offering the video could not redact it, and
  • the officer’s comments were not offered for their truth but as “context” or “completion,” likening them to bystanders’ real‑time comments on the George Floyd video (“they’re killing him”).

C. Court of Appeals and Supreme Court

The Commonwealth appealed under KRS 22A.020(4). The Court of Appeals reversed, holding that:

• Lanham was distinguishable; it involved interrogation techniques directed at a suspect, not testimonial statements about a victim’s credibility.
• The officer’s comments on the body‑cam were inadmissible credibility opinions.
• The trial court erred by ordering the entire video to be admitted wholesale if any portion was offered.

The Supreme Court granted discretionary review and:

• Rejected Hartsfield’s preservation argument, finding the legal issue sufficiently framed.
• Affirmed the Court of Appeals, holding that:
  • The officer’s credibility opinions about B.B. are inadmissible.
  • The trial court abused its discretion both in denying the motion in limine and in ruling that the entire body‑cam video must be admitted.

III. Detailed Analysis

A. Precedents and Authorities Relied Upon

1. Evidentiary Framework: KRE 701, 801–803

• KRE 801(c) defines hearsay as an out‑of‑court statement offered “to prove the truth of the matter asserted.”
• KRE 802 provides that hearsay is generally inadmissible unless an exception applies.
• KRE 803(1)–(2) define two relevant non‑exclusionary categories:
  • Present sense impression: statements describing or explaining an event made while perceiving it or immediately thereafter.
  • Excited utterance: statements relating to a startling event made while under the stress of excitement caused by it.
• KRE 701 allows a lay witness to give opinion testimony only if it is:
  • rationally based on the witness’s perceptions,
  • helpful to understanding the testimony or determining a fact in issue, and
  • not based on specialized knowledge within the scope of expert testimony.

The defense invoked KRE 701 to justify the officer’s comments as rational, perception‑based lay opinions (“she seems untruthful”; “this looks like a hickey”). The Supreme Court acknowledges KRE 701 but emphasizes a separate and overriding line of authority prohibiting opinion testimony on another witness’s veracity or on the defendant’s guilt.

2. The “Human Lie Detector” Line: Moss, Ordway, Carson, Brown, Nugent, Hall

Kentucky has a long and consistent line of cases sharply limiting opinion testimony about credibility and guilt:

• Moss v. Commonwealth, 949 S.W.2d 579 (Ky. 1997):
  • Held that a witness must not be required to characterize another witness’s testimony as “lying.”
  • Articulated the principle, later quoted verbatim in Hartsfield (via Carson), that:

    “With few exceptions, it is improper to require a witness to comment on the credibility of another witness. A witness’s opinion about the truth of the testimony of another witness is not permitted. Neither expert nor lay witnesses may testify that another witness or a defendant is lying or faking. That determination is within the exclusive province of the jury.”

• Ordway v. Commonwealth, 391 S.W.3d 762 (Ky. 2013):
  • Reaffirmed Moss and emphasized that it is “generally improper for a witness to characterize the testimony of another witness as ‘lying’ or otherwise.”
  • Cited Lanham, Moss, Hall, and other cases as part of a well‑settled principle.
• Carson v. Commonwealth, 621 S.W.3d 443 (Ky. 2021):
  • Summarized the rule by explicitly rejecting “human lie detector” testimony:

    “One area in which neither lay nor expert testimony is appropriate is the veracity of a witness. Just as we prohibit the introduction of mechanical polygraphic evidence, we similarly restrict the ability of a witness to act as a human lie detector on the stand.”

  • Re‑quoted the Moss rule that neither expert nor lay witnesses may testify that another witness is lying or faking.
• Brown v. Commonwealth, 718 S.W.3d 776 (Ky. 2025) (as quoted in Hartsfield):
  • Reiterated:

    “It is well settled that a witness cannot vouch for the truthfulness of another witness either directly or indirectly.”

  • This encompasses both explicit statements (“she’s telling the truth”) and more subtle implied vouching.
• Nugent v. Commonwealth, 639 S.W.2d 761 (Ky. 1982):
  • Held that witnesses cannot opine directly on the defendant’s guilt or innocence.
  • Condemned attempts to introduce such opinions “through a route which is, at best, ‘back door’ in nature.”
  • Emphasized that guilt is “one for the jury to determine” and opinion evidence intruding on that function is incompetent.
• Hall v. Commonwealth, 337 S.W.3d 595 (Ky. 2011):
  • Cited in Ordway as another authority reinforcing the prohibition on one witness commenting on another’s credibility.

Hartsfield applies these cases to the new context of body‑cam recordings: if an officer could not testify live, “I think the victim is lying” or “I don’t believe her,” then a video of the officer saying the same thing cannot be played to the jury.

3. Lanham and the “Interrogation Context” Exception

The crucial precedential battleground in Hartsfield is Lanham v. Commonwealth, 171 S.W.3d 14 (Ky. 2005), which addressed:

• whether an officer’s accusatory statements to a suspect during a recorded custodial interrogation (e.g., “you’re lying”) must be redacted before being played to a jury, and
• whether such statements are impermissible opinion evidence.

Lanham held:

• Officer accusations of lying within an interrogation are:
  • a “legitimate, even ordinary, interrogation technique,” and
  • often necessary to provide “context” for the defendant’s recorded statements (i.e., to understand what the defendant is responding to).
• Such comments are not admissible for their truth (the officer’s belief that the defendant is in fact lying), but may be admitted for the limited purpose of context, accompanied by an admonition.
• Importantly, Lanham explicitly limited its holding:

  “Our holding in this case, and the rule that it establishes, is limited to the types of comments in this case, i.e., accusations by an officer that a defendant is not telling the truth.”

The trial court in Hartsfield read Lanham broadly to support admitting the officer’s body‑cam comments about B.B.’s credibility for “context.” The Supreme Court rejects this, emphasizing:

• Lanham involved non‑testimonial interrogation tactics directed at a suspect, not testimonial evaluation of a third‑party victim.
• The officer’s comments in Lanham were “suggestive rather than testimonial”; here, they are “wholly testimonial in nature.”
• The Lanham context rule is tightly confined to its facts and does not justify admitting officers’ out‑of‑court credibility assessments about witnesses or victims.

4. Investigative Hearsay: Ruiz and Colvard

To address defense arguments that the officer’s statements were needed “to show context” of the investigation, the Court cites:

• Ruiz v. Commonwealth, 471 S.W.3d 675 (Ky. 2015):
  • Rejected an “investigative hearsay” theory under which officers could recount out‑of‑court statements as “background” explaining the course of their investigation.
  • Emphasized that there is no “investigative hearsay” exception to the hearsay rule.
• Colvard v. Commonwealth, 309 S.W.3d 239 (Ky. 2010):
  • Similarly rejected an “investigatory” hearsay exception for social workers recounting statements made to them.

Hartsfield extends these principles into the body‑cam context, insisting that:

• There is no “context” or “investigatory” hearsay exception for recorded investigative commentary.
• Out‑of‑court statements captured on video must meet an established exception (e.g., present sense impression, excited utterance) or be excluded.

5. Standard of Review: Goodyear Tire v. Thompson

On the standard of review, the Court cites Goodyear Tire & Rubber Co. v. Thompson, 11 S.W.3d 575 (Ky. 2000), for the proposition that evidentiary rulings are reviewed for abuse of discretion. A trial court abuses its discretion when it:

• makes a decision that is arbitrary or unreasonable, or
• applies the wrong legal standard to the facts.

Here, by:

• treating the officer’s credibility opinions as admissible “context,” and
• directing that the entire body‑cam be admitted without viewing or parsing the footage,

the trial court misapplied the governing legal principles, amounting to an abuse of discretion.

B. The Court’s Legal Reasoning

1. Preservation: Was the Motion in Limine Too Vague?

Hartsfield argued that the Commonwealth failed to preserve its objection because it:

• did not play the exact portion of the video at the motion hearing, and
• did not quote verbatim the officer’s statements it sought to exclude.

He also suggested the Commonwealth might be trying—impermissibly—to preclude testimony that the neck mark appeared to be a “hickey.”

The Supreme Court rejected this preservation challenge, reasoning:

• The issue presented was a legal one: may an officer offer an opinion on the veracity of a witness as to what occurred? That question does not require the appellate court to see the actual footage.
• The Commonwealth clarified at the hearing that it was not trying to exclude observations about the physical mark on B.B.’s neck; it sought only to exclude the officer’s opinions about B.B.’s truthfulness.
• There is no indication that either party or the trial court was confused about what portion of the video was at issue.
• Vacating to require the trial court to watch the video would cause needless delay without changing the purely legal analysis.

Thus, the Court proceeded to the merits.

2. Hearsay First: No “Context” or “Body‑Cam” Exception

Before addressing credibility‑opinion issues, the Court insists on starting where any analysis of recorded statements must start: hearsay.

The key moves:

• The officer’s body‑cam comments are out‑of‑court statements.
• They are hearsay if offered to prove the truth of the matter asserted (e.g., that B.B. is lying).
• Hearsay is inadmissible unless an exception applies.
• There is no special hearsay exception for:
  • “context,” or
  • “investigatory” or “investigative hearsay.”
• The present sense impression and excited utterance exceptions do not apply because:
  • Unlike the George Floyd bystander statements (real‑time exclamations about an ongoing event), the officer’s statements here are reflective and analytical—made after an initial investigation of the scene and a reported crime.
  • The officer is not describing an unfolding event under stress but evaluating the plausibility of B.B.’s account.
• “Context” alone is not a recognized hearsay exception. There is no “context exception” in KRE 803.

Therefore:

“If the statements contained [in a body‑cam recording] would not be appropriately admitted if testified to by a sworn witness at trial under our evidentiary rules, they cannot be admissible simply because they were recorded.”

That principle is foundational to the Court’s approach to body‑cam evidence.

3. Credibility Opinions: No Human Lie Detectors, Live or Recorded

Once the Court establishes that hearsay principles apply, it turns to the substantive nature of the statements: opinions about another witness’s truthfulness and about whether a crime occurred.

From Carson, Moss, Ordway, Brown, and Nugent, the Court reiterates:

• No witness—lay or expert—may testify that:
  • another witness is or is not telling the truth, or
  • a defendant is or is not guilty.
• Such determinations lie within the “exclusive province of the jury.”
• Witnesses cannot function as “human lie detectors,” and their opinions on guilt cannot be smuggled in “through a back door” route.

Crucially, the Court states:

“If a live witness would not be allowed to provide testimony opinion about another witness’s veracity, a recorded statement of that same person giving the same prohibited opinion cannot be admitted into evidence.”

In other words:

• Body‑cam technology does not create a new evidentiary category immune from traditional limits.
• The “human lie detector” prohibition applies equally to:
  • in‑court statements, and
  • out‑of‑court recorded statements.

Allowing the jury to hear an officer opine that B.B. was not truthful would risk the jury deferring to the officer’s judgment rather than making its own independent credibility assessment. That is precisely what the line of cases from Moss to Carson forbids.

4. Narrowing Lanham: Interrogation v. Testimonial Commentary

The trial court had leaned heavily on Lanham, asserting that the officer’s statements here were akin to interrogation‑stage accusations that had to be kept in the recording “for context” or “completion.” The Supreme Court directly rejects this analogy.

Key distinctions:

• Who is speaking about whom?
  • Lanham: officers confronted the defendant with accusations during an interrogation, as part of an effort to elicit a confession or clarify his story.
  • Hartsfield: officers, in conversation with each other, expressed opinions about the alleged victim’s credibility.
• Purpose of the statements:
  • Lanham: statements functioned as interrogation tactics; they were not offered (and not admissible) for the truth of the accusation but to contextualize the defendant’s responses.
  • Hartsfield: statements are testimonial credibility assessments—direct officer opinions about whether B.B. is truthful—that the defense clearly wants the jury to accept as substantive evidence undermining her credibility.
• Timing and setting:
  • Lanham: within a structured custodial interrogation, where accusatory questions are expected tools.
  • Hartsfield: not part of an interrogation, not directed to the victim, and not necessary to understand any recorded responses.

The Court emphasizes that Lanham itself restricted its rule to the context of interrogation accusations against a suspect and that the statements in Hartsfield are “wholly testimonial” credibility opinions about a third party. As such, Lanham offers no shelter.

5. Rejection of the “Completeness” / “Context” Rationale

The trial court characterized the officer’s opinion as admitted not “for the truth of the matter asserted” but as “context” or “completion” of the body‑cam video. The Supreme Court is not persuaded.

The concern is straightforward:

• Whatever label is used (“context,” “completion”), the effect on the jury is that it hears a police officer declare that he does not believe the alleged victim.
• The risk is that jurors, who may be inclined to credit police opinions, will give undue weight to that statement and may decide credibility based on the officer’s assessment rather than their own evaluation.
• This is exactly what the credibility‑opinion cases prohibit.

Thus, the Court holds that such statements “must be excluded.” An admonition limiting their use to “context” cannot convert substantively inadmissible credibility opinions into admissible evidence.

6. Body‑Cam Management: Against Wholesale Admission

Beyond the specific credibility issue, the Court uses this case to give more general guidance on handling body‑worn camera evidence:

• The Kentucky Rules of Evidence contain no “blanket admission” rule for body‑cams.
• Body‑cams often contain a mixture of:
  • admissible statements (e.g., some excited utterances or present sense impressions),
  • inadmissible hearsay, and
  • other problematic content (e.g., opinions, speculation, “human lie detector” remarks).
• Therefore, trial courts should:
  • avoid ordering wholesale admission of entire videos, and
  • instead conduct in camera review (private review by the judge with counsel) to:
    • identify admissible segments,
    • exclude inadmissible parts, and
    • ensure appropriate redaction before the jury sees anything.

The Court explicitly notes:

“In general, when there is something pertinent to be viewed from the body worn camera footage, rather than the wholesale admission of such video, an in camera examination should be conducted by the court and counsel, limiting the footage to admissible portions.”

This is a significant procedural directive to Kentucky trial judges and practitioners about handling the increasingly common problem of voluminous digital recordings.

7. Issues Left Open

The Court deliberately limits its holding and flags issues it is not deciding:

• Whether officers may give lay opinion testimony at trial about the cause of the mark on B.B.’s neck (e.g., “it looked like a hickey” versus evidence of strangulation).
• Whether, and how, prior inconsistent statements on body‑cam (e.g., an officer’s earlier comment that the mark looked like a hickey) may later be used to impeach trial testimony.

The Court’s analysis is confined to:

• whether the trial court erred in:
  • denying the Commonwealth’s motion in limine to exclude the officer’s opinion on B.B.’s veracity, and
  • ordering wholesale admission of the entire body‑cam if any portion were offered.

C. Impact and Future Significance

1. Clarifying the Law of Body‑Cam Evidence in Kentucky

Hartsfield gives Kentucky courts and litigants a clear framework:

• No special rules for body‑cams: recordings are governed by the same hearsay and opinion‑testimony rules as any other evidence.
• Trial courts must avoid a “play everything” approach; they are expected to:
  • screen recordings, and
  • admit only those segments that independently satisfy the Kentucky Rules of Evidence.
• Police‑recorded opinions that a victim or witness is lying or telling the truth are inadmissible and must be redacted.

This will shape how law enforcement, prosecutors, and defense counsel:

• train officers on what they say while recording,
• draft motions in limine specifically targeting problematic segments, and
• prepare redacted video for trial.

2. Sexual Assault and “He Said/She Said” Cases

In sexual assault cases, credibility is often central. Defense strategies sometimes seek to leverage:

• initial police skepticism
• or perceived inconsistencies in the complainant’s account

to argue reasonable doubt. Hartsfield makes clear:

• Defendants may still attack a complainant’s credibility through:
  • cross‑examination,
  • inconsistencies in the complainant’s own statements,
  • objective evidence, and
  • permissible lay or expert testimony (e.g., medical findings).
• But they may not call a police officer as a surrogate “lie detector,” whether live or via body‑cam, to tell the jury the officer does or does not believe the complainant.

From the prosecution perspective, the ruling:

• protects victims from having their credibility undermined by an officer’s off‑hand skepticism caught on video, and
• prevents the trial from being distorted by the personal beliefs of law enforcement recorded in the heat of an early investigation.

3. Law Enforcement Training and Practice

Practically, police departments may:

• train officers to avoid voicing opinions on victims’ or suspects’ truthfulness while recording,
• encourage factual descriptions (“she said X; I observed Y”) rather than evaluative judgments (“I think she’s lying”), and
• coordinate with prosecutors on redaction protocols before trial.

Officers’ on‑scene judgments still matter operationally, but Hartsfield signals that those judgments rarely belong before a jury as evidence.

4. Trial Practice and Appellate Strategy

For trial lawyers:

• For the Commonwealth:
  • File targeted motions in limine early, identifying categories of inadmissible content (credibility opinions, hearsay not covered by an exception, inflammatory remarks).
  • Prepare redacted versions in advance and be ready to walk the court through them in camera.
• For the defense:
  • Recognize that you cannot admit an officer’s opinion that a victim is lying as substantive evidence.
  • Focus instead on:
    • objective contradictions,
    • inconsistencies in the victim’s own statements, or
    • legitimate impeachment uses of prior inconsistent statements (subject to hearsay and other rules).

Appellate lawyers will note that:

• The Court treated the admissibility of police veracity opinions captured on video as a pure legal question, suitable for review even without the video itself.
• This may encourage more targeted pretrial appeals on similar issues under KRS 22A.020(4) when the Commonwealth faces adverse rulings on critical evidentiary points.

5. Relationship to Constitutional Concerns

The Court resolves this case on state evidentiary grounds and does not rely on federal confrontation or due process doctrines. But the opinion’s insistence that:

• there is no “investigative hearsay” or “context” exception, and
• testimonial statements of officers about witness credibility are inadmissible,

helps ensure that body‑cam practices remain consistent with the Confrontation Clause as interpreted in Crawford v. Washington and its progeny, without needing to invoke those federal cases explicitly.

IV. Complex Concepts Simplified

1. Motion in Limine

A motion in limine is a pretrial request asking the judge to rule that certain evidence:

• must not be mentioned or introduced at trial, or
• may only be used for a limited purpose.

Here, the Commonwealth used a motion in limine to try to keep the officer’s credibility opinions about B.B. off the body‑cam video from ever reaching the jury.

2. Hearsay and Its Exceptions

Hearsay is:

• an out‑of‑court statement
• offered to prove the truth of what it asserts.

Example: An officer testifying, “The victim told me he was strangled,” offered to show that he was strangled, is hearsay. Hearsay is usually not allowed because:

• the original speaker is not in court to be cross‑examined, and
• the jury cannot observe their demeanor.

Some exceptions allow hearsay if the circumstances make the statement reliable, such as:

• Present sense impression: “He’s strangling me right now!” shouted while the event is happening.
• Excited utterance: A frantic 911 call immediately after an attack.

Hartsfield explains that an officer’s after‑the‑fact opinion—“I don’t believe her story”—does not fit these exceptions; it’s not a contemporaneous description of an event or a spontaneous reaction to it.

3. Lay Opinion (KRE 701)

Lay witnesses are non‑experts. Under KRE 701, they can sometimes offer opinions, but only if:

• the opinion is based on what they personally saw or heard, and
• it helps the jury understand something (e.g., “He looked drunk”; “The car was going fast”).

However, there is a major limit: lay witnesses cannot opine on:

• whether another witness is lying, or
• whether the defendant is guilty.

Those are for the jury alone. This is why an officer’s opinion that “she’s making it up” is inadmissible, no matter how “perception‑based” it may be.

4. Vouching and “Human Lie Detector” Testimony

Vouching is when one witness tells the jury that another witness is or is not telling the truth. It can be:

• Direct (“I believe her”; “I think he’s lying”), or
• Indirect (offering an opinion that clearly implies a credibility judgment).

Courts reject “human lie detector” testimony because:

• jurors are supposed to decide who is credible,
• police or expert opinions might unduly sway the jury, and
• it blurs the line between witness and juror roles.

Hartsfield applies this principle to recorded statements: a body‑cam cannot be used to smuggle in what a live officer could not say from the stand.

5. In Camera Review

An in camera review means the judge looks at a piece of evidence privately (usually with counsel present) before deciding whether the jury will see it. With body‑cams, this often involves:

• watching the video,
• identifying which parts are admissible, and
• ordering redactions of inadmissible portions (e.g., hearsay, credibility opinions, inflammatory comments).

The jury then sees only the edited, admissible segments.

6. “Context” in Evidence Law

“Context” can legitimately matter in evidence law; for example:

• Under the rule of completeness (KRE 106), if one party plays part of a recorded statement, the other party may be allowed to introduce additional parts needed to prevent the first part from being misleading.

But “context” is not a free‑standing hearsay exception. It does not automatically justify admitting otherwise inadmissible testimony. Lanham allowed limited use of interrogation officers’ statements to give context to a defendant’s responses, but Hartsfield makes clear that this narrow rule:

• does not extend to officers’ testimonial opinions about a victim’s veracity, and
• cannot be used as a general “context” exception for body‑cam content.

7. Abuse of Discretion

Courts give trial judges some leeway (discretion) to make evidentiary rulings. But an appellate court will reverse if the judge:

• applies the wrong legal rule, or
• makes a decision that is unreasonable or arbitrary.

In Hartsfield, the Supreme Court found an abuse of discretion because the trial court:

• treated inadmissible credibility opinions as admissible “context,” and
• ordered that the entire body‑cam be played, without viewing it or screening out inadmissible portions.

V. Conclusion: Key Takeaways

Hartsfield v. Commonwealth is a significant, clarifying decision for Kentucky evidence law in the digital age. Its core holdings can be distilled as follows:

• No officer “veracity opinions” via body‑cam. Police officer statements on body‑cam videos that express belief or disbelief in a victim’s or witness’s account are inadmissible. If an officer could not say it live on the stand, the jury cannot see it on a recording.
• Lanham is narrow. The limited allowance in Lanham for accusatory interrogation comments to be played for “context” does not extend to testimonial credibility assessments about victims or witnesses captured on body‑cams.
• No “context” or “investigative hearsay” exception. Hearsay rules apply fully to body‑cam content. There is no general exception permitting out‑of‑court statements simply to show investigative “context.”
• Body‑cam footage must be parsed, not played wholesale. Trial courts should use in camera review to identify and admit only those portions of recordings that satisfy the Kentucky Rules of Evidence, excluding hearsay, credibility opinions, and other inadmissible material.
• Credibility remains for the jury. Echoing a long line of precedent, the Court reinforces that determinations of who is lying, who is telling the truth, and whether a defendant is guilty remain the exclusive responsibility of the jury.

As police video becomes central in criminal trials, Hartsfield provides crucial guardrails ensuring that technological advances do not erode fundamental evidentiary principles. It offers clear guidance to judges, prosecutors, defenders, and law enforcement alike: body‑worn cameras record, but they do not rewrite, the rules of evidence.