| Williams v. State, 261 Ga. 640 (1991) |
Standard for admitting evidence of a similar transaction (nexus/similarity required). |
Court held that without the 1990 police report the State did not meet the Williams standard to admit similar-transaction evidence. |
| Stephens v. State, 261 Ga. 467 (1991) |
Certified conviction alone is insufficient to establish the required nexus for similar-transaction evidence. |
Used to explain that the certified 1990 conviction standing alone did not satisfy the nexus requirement. |
| OCGA § 24-3-14 |
Georgia statute governing business records exception to hearsay. |
Framework for analyzing whether the police report narrative qualified as a business record; Court concluded narratives generally lack the trustworthiness required. |
| Martin v. Baldwin, 215 Ga. 293 (1959) |
Characteristics documents should have to be business records—"routine facts" unaffected by bias, judgment, memory. |
Cited to explain why police report narratives, often subjective, do not fit the reliable "business record" paradigm. |
| Gann v. State, 190 Ga. App. 82 (1989) |
Court of Appeals precedent holding police reports may be admissible as business entries where proper foundation is laid. |
Noted as one of the Court of Appeals cases the Supreme Court overruled to the extent they allowed police report narratives as business records. |
| Reed v. Heffernan, 171 Ga. App. 83 (1984) |
Similar Court of Appeals authority regarding admissibility of police reports. |
Identified among cases the majority declined to follow to the extent they permitted narrative admissions. |
| Johnson v. State, 168 Ga. App. 271 (1983) |
Another Court of Appeals case concerning police reports and hearsay. |
Included in the list of appellate decisions the Supreme Court observed and limited. |
| Pickett v. State, 123 Ga. App. 1 (1970) |
Prior appellate decision regarding police reports and admissibility. |
Listed among the cases the Court said are overruled to the extent they permit narrative police reports as business records. |
| Johnson v. State, 247 Ga. App. 660 (2001) |
Appellate treatment relevant to police report admissibility (cited by majority). |
Referenced among cases Supreme Court addressed and limited. |
| Shoney's, Inc. v. Hudson, 218 Ga. App. 171 (1995) |
Appellate precedent cited concerning business-records-admissibility issues. |
Included in the list of decisions the majority restricted as to narrative police reports. |
| Curtis v. State, 190 Ga. App. 173 (1989) |
Appellate decision on police report admissibility. |
Listed among cases limited by the Court. |
| Fine v. APAC-Georgia, Inc., 192 Ga. App. 895 (1989) |
Appellate authority on business records evidence. |
Included among cases the Supreme Court said are limited as to police report narratives. |
| Johnson v. Dallas Glass Co., 183 Ga. App. 584 (1987) |
Appellate case on business-records issues. |
Listed in the majority's catalog of cases to which it declined to extend the business-records exception for narratives. |
| Jones v. Davis, 183 Ga. App. 401 (1987) |
Appellate authority referenced in the majority's survey. |
Included among cases the Court contrasted with its holding. |
| Estes v. State, 165 Ga. App. 453 (1983) |
Appellate precedent concerning police reports. |
Listed as part of appellate landscape the Supreme Court limited. |
| Bramblett v. State, 139 Ga. App. 745 (1976) |
Earlier appellate decision on hearsay/business-records topics. |
Included among cases the Court cited and restricted in application to police narratives. |
| Calhoun v. Chappell, 117 Ga. App. 865 (1968) |
Appellate case touching on business records/hearsay principles. |
Part of the list of prior appellate rulings the majority declined to follow for narrative admissions. |
| Stubbs v. Daughtry, 115 Ga. App. 22 (1967) |
Older appellate authority on substantive hearsay issues. |
Included in the catalog of cases the Court limited as to narrative police reports. |
| Palmer v. Hoffman, 318 U.S. 109 (1943) |
U.S. Supreme Court decision refusing to admit railroad accident reports as business records; focused on reliability and "earmarks of reliability." |
Cited as persuasive authority analogizing police report narratives to railroad accident reports and supporting exclusion due to lack of inherent reliability. |
| Reeves v. King, 554 So.2d 1107 (Ala. 1988) |
State authority disapproving admission of police reports under business-records exception. |
Noted as one of several out-of-state decisions disfavoring admission of police narratives as business records. |
| Wilson v. State, 756 P.2d 307 (Alas. 1988) |
State decision similarly disapproving police reports as business records when used by prosecution. |
Listed among authorities from other jurisdictions supporting the majority's position. |
| Wallin v. Ins. Co. of North America, 268 Ark. 847 (596 S.W.2d 716) (1980) |
Out-of-state precedent concerning business-records admissibility. |
Included as part of the comparative authorities rejecting admission of investigative narratives as business records. |
| Bolin v. State, 736 So.2d 1160 (Fla. 1999) |
State-level rejection of police-report narratives as business records. |
Noted among decisions from other states that disallow such admissions. |
| People v. Gayton, 293 Ill. App.3d 442 (1997) |
Appellate authority in Illinois critical of police-report-as-business-record admissions. |
Referenced in the survey of persuasive out-of-state authority. |
| Bacher v. State, 686 N.E.2d 791 (Ind. 1997) |
Indiana decision noting concerns about police reports and hearsay. |
Cited among other jurisdictions tending to disapprove admission of narrative reports. |
| State v. Smith, 594 So.2d 467 (La. 1991) |
Louisiana court addressing police reports and hearsay. |
Included as supportive out-of-state authority. |
| Solomon v. Shuell, 435 Mich. 104 (1990) |
Michigan Supreme Court decision critical of treating investigative reports as business records. |
Listed among decisions the majority cited for the proposition that investigative narratives are unreliable for the business-records exception. |
| Snyder v. Portland Traction Co., 182 Or. 344 (1947) |
Older authority discussing limits of business-records admissions. |
Cited as part of the broader out-of-state authority the majority relied on. |
| State v. Bertul, 664 P.2d 1181 (Utah 1983) |
Utah decision noting concerns and emphasizing cross-examination where report prepared partly with prosecution in mind. |
Cited in the majority and concurrence addressing reasons to be cautious admitting investigative narratives. |
| Montgomery v. U.S., 517 A.2d 313 (D.C. 1986) |
Case distinguishing police reports prepared in anticipation of litigation from routine administrative entries. |
Referenced as authority distinguishing admissible routine entries from inadmissible investigative narratives. |
| Ohio v. Roberts, 448 U.S. 56 (1980) |
U.S. Supreme Court case on confrontation clause and reliability of hearsay exceptions. |
Used to emphasize confrontation-right concerns if investigative reports routinely replace live testimony. |
| Livingston v. State, 268 Ga. 205 (1997) |
Statement about out-of-court statements within firmly-rooted hearsay exceptions meeting constitutional reliability requirements; also cited about sufficiency rule excluding hearsay. |
Cited to explain constitutional reliability concerns and that hearsay cannot be considered in determining sufficiency of the evidence. |
| Momon v. State, 249 Ga. 865 (1982) |
Hearsay admissible to explain conduct where the actor's conduct and motive are matters concerning which the truth must be found. |
Foundation for the limited exception permitting hearsay to explain an actor's conduct; Court applied this principle narrowly. |
| Teague v. State, 252 Ga. 534 (1984) |
Refinement that only in rare instances will an investigating officer's conduct need explanation; caution against expansive use of OCGA § 24-3-2. |
Used to conclude the present case was not one of the rare instances justifying admission of hearsay to explain officer conduct. |
| Weems v. State, 269 Ga. 577 (1998) |
Reiterated limits on admitting hearsay to explain police conduct even where a confidential informant initiated an investigation. |
Relied upon to support exclusion of the arresting officer's hearsay about the anonymous tip. |
| White v. State, S00G1572 (decided May 7, 2001) |
Recent restatement that certain officer testimony (identification in a lineup) was not admissible as original evidence to explain conduct. |
Referenced as recent authority reinforcing the narrow application of the "explain conduct" exception. |
| Greene v. State, 266 Ga. 439 (1996) (overruled on other grounds) |
Example where hearsay was admitted to explain a sheriff's conduct in employing additional security measures. |
Used for comparison, illustrating the narrow class of cases where such hearsay may be allowed. |
| Greene v. Georgia, 519 U.S. 145 (1996) |
Noted as overruling Greene on other grounds. |
Mentioned parenthetically to indicate subsequent treatment of Greene. |
| George v. State, 242 Ga. App. 580 (2000) |
Case admitting hearsay to explain officer conduct where defendant alleged fabrication in retaliation. |
Compared as another example of a limited circumstance in which the exception was applied. |
| Anderson v. State, 247 Ga. 397 (1981) |
Principle that hearsay admitted to explain conduct is not admissible as evidence of guilt. |
Cited to stress that even if properly admitted to explain conduct, such evidence cannot be treated as proof of guilt. |
| Harrell v. State, 241 Ga. 181 (1978) |
Similar principle that hearsay explaining conduct is not evidence of guilt. |
Used to reinforce limits on the evidentiary use of hearsay admitted under OCGA § 24-3-2. |
| Brown v. State, 245 Ga. App. 149 (537 S.E.2d 421) (2000) |
The Court of Appeals' decision under review (summary of evidence and affirmance). |
Supreme Court reviewed and reversed the Court of Appeals' rulings concerning admission of the police report narrative and the hearsay explaining officer conduct. |
| United States v. Brown, 9 F.3d 907 (11th Cir. 1993) |
Discussion distinguishing routine, objective police records from investigative narratives. |
Appears in concurrence to support the view that routine police entries may be admissible while investigative narratives are not. |
| People v. Guidice, 634 N.E.2d 951 (N.Y. 1994) |
Authority recognizing admissibility of routine, nonadversarial police-record entries. |
Appears in the concurrence as an example of courts treating routine administrative entries differently from investigative narratives. |
| State ex rel. Mack v. Purkett, 825 S.W.2d 851 (Mo. 1992) |
Distinction that merely identifying an arrested person is less subject to perception/memory dangers than investigative details. |
Used in concurrence to illustrate the routine/objective vs. subjective/investigative distinction. |
| State v. Best, 703 P.2d 548 (Ariz.App. 1985) |
Example of jurisdictional treatment of police records. |
Referenced in concurrence as supportive authority for distinguishing categories of police records. |
| People v. Guidice (repeated in concurrence) |
See above. |
Reiterated in concurrence discussion. |