Blackledge v. State (2016)

But the general rule under the old and current codes is that “documents from electronic sources . . . are subject to the same rules of authentication as other more traditional documentary evidence and may be authenticated through circumstantial evidence.” 5 The Attorney General in his brief here cites former OCGA 24-3-31, which provided that, with some exceptions, an “admission by a party to the record shall be admissible in evidence when offered by the other side[.]” 18 Bla…

“The trial court’s rulings on the exclusion or admission of evidence are reviewed for a clear abuse of discretion.” (Citation and punctuation omitted.) Riggs v. State, 306 Ga. 759, 762 (2) ( 833 SE2d 112 ) (2019). 18 Our Supreme Court has explained that “documents from electronic sources such as the printouts from a website like MySpace are subject to the same rules of authentication as other more traditional documentary evidence and may be authenticated through circumstanti…

Blackledge v. State, 299 Ga. 385, 387-388 ( 788 SE2d 353 ) (2016) (citations and punctuation omitted).

Given this testimony, Bradford has failed to show that a proper foundation was lacking to preclude the admission of the cell phone records as business records as an exception to the hearsay rule under former OCGA § 24-3-14. 15 See, e.g., Blackledge v. State, 299 Ga. 385, 391 (2016) (cell phone records custodian testified that records were made in the regular course of business at or near the time that the phone calls were made and the cell towers detected the presence of the…

Given this testimony, Bradford has failed to show that a proper foundation was lacking to preclude the admission of the cell phone records as business records as an exception to the hearsay rule under former OCGA § 24-3-14. 15 See, e.g., Blackledge v. State, 299 Ga. 385, 391 (2016) (cell phone records custodian testified that records were made in the regular course of business at or near the time that the phone calls were made and the cell towers detected the presence of the…

See Chavez v. State, 307 Ga. 804, 806 (1) n.3 ( 837 SE2d 766 ) (2020); Blackledge v. State, 299 Ga. 385, 387 (1) n.3 ( 788 SE2d 353 ) (2016); Mills v. State, 287 Ga. 828, 830 (2) ( 700 SE2d 544 ) (2010). 8 The State contends that the record does not show that Frazier objected to the admission of the Rule 404 (b) evidence and that this Court should review evidence for the purposes of showing intent, plan, and preparation.

He must make a clear showing that a joint trial would lead to prejudice and a consequent denial of due process.” (Citation and punctuation omitted.) Blackledge v. State, 299 Ga. 385, 388 (2) ( 788 SE2d 353 ) (2016).

He must make a clear showing that a joint trial would lead to prejudice and a consequent denial of due process.” Blackledge v. State, 299 Ga. 385, 388 (2) ( 788 SE2d 353 ) (2016) (citation and punctuation omitted).

“In ruling on a severance motion, the court should consider: (1) the likelihood of confusion of the evidence and law; (2) the possibility that evidence against one defendant may be considered against the other defendant; and (3) the presence or absence of antagonistic defenses.” [Cit.] Blackledge v. State, 299 Ga. 385, 387 (2) ( 788 SE2d 353 ) (2016).

“In ruling on a severance motion, the court should consider: (1) the likelihood of confusion of the evidence and law; (2) the possibility that evidence against one defendant may be considered against the other defendant; and (3) the presence or absence of antagonistic defenses.” [Cit.] Blackledge v. State, 299 Ga. 385, 387 (2) ( 788 SE2d 353 ) (2016).

Blackledge v. State, 299 Ga. 385, 391 (5) ( 788 SE2d 353 ) (2016). (a) Satterfield’s trial was held in January 2014 and was therefore governed by the new Evidence Code.

See Blackledge v. State, 299 Ga. 385, 391 (4) ( 788 SE2d 353 ) (2016) (holding that 15 printouts of posts from users’ MySpace pages were properly authenticated where officer testified that he used known identifying information about the users to locate their pages, that the printouts were an accurate representation of what was posted on those pages, and that the photographs posted on the pages depicted the users); Cotton v. State, 297 Ga. 257, 259-260 (3) ( 773 SE2d 242 ) (2…

See Blackledge v. State, 299 Ga. 385, 390-391 (4) ( 788 SE2d 353 ) (2016). relevant evidence may be excluded under OCGA § 24-4-403 (“Rule 403”) “if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” The photograph was relevant to show that Lyons, at some point, possessed the type of gun used in t…

See Blackledge v. State, 299 Ga. 385, 387 (1) n.3 ( 788 SE2d 353 ) (2016). 6 (a) Chavez was charged with violating the Street Gang Act on the basis that, while associated with a criminal street gang, he participated in criminal gang activity through the commission of at least one of several crimes: murder, felony murder, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony.

See Blackledge v. State, 299 Ga. 385, 387 (1) n.3 ( 788 SE2d 353 ) (2016); Browder, 294 Ga. at 191 (1).

See Blackledge v. State, 299 Ga. 385, 387 (1) n.3 ( 788 SE2d 353 ) (2016).3 2 The cases cited by Daniels do not demand a contrary result.

See Blackledge v. State, 299 Ga. 385, 390 (3) ( 788 SE2d 353 ) (2016).

See Blackledge v. State, 299 Ga. 385, 390 (3) ( 788 SE2d 353 ) (2016).