business record exception (North Carolina) · Go Syfert
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business record exception in North Carolina

7 North Carolina opinions name it 1 courts 2011–2025 4 in the last five years

The cases below were cited by North Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
State v. Wilsongreen
nc · 1985 · cited in 1 North Carolina opinions naming this issue, 2024–2024
2 sentences

2024The records must be “authenticated by a witness who is familiar with them and the system under which they are made.” State v. Wilson, 313 N.C. 516, 533 , 330 S.E.2d 450, 462 (1985) (citations omitted).

2024The records must be “authenticated by a witness who is familiar with them and the system under which they are made.” State v. Wilson, 313 N.C. 516, 533 , 330 S.E.2d 450, 462 (1985) (citations omitted).

11
State v. Canadygreen
nc · 1991 · cited in 1 North Carolina opinions naming this issue, 2020–2020
2 sentences

2020The purpose of preservation rules “is to require a party to call the court’s attention to a matter upon which he or she wants a ruling before he or she can assign error to the matter on appeal.” State v. Canady, 330 N.C. 398, 401 , 410 S.E.2d 875, 878 (1991).

2020The purpose of preservation rules “is to require a party to call the court’s attention to a matter upon which he or she wants a ruling before he or she can assign error to the matter on appeal.” State v. Canady, 330 N.C. 398, 401 , 410 S.E.2d 875, 878 (1991).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Carolina. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
In Re SDJ green
ncctapp · 2008
2 sentences

2022App. 478 , 665 S.E.2d 818 (2008), this Court held that the results of a drug test were properly admitted under the business record exception to the hearsay rule.

2022App. 478 , 665 S.E.2d 818 (2008), this Court held that the results of a drug test were properly admitted under the business record exception to the hearsay rule.

22022–2022
State v. Sharpe green
nc · 1996
2 sentences

2020Finally, although the trial court made a thorough ruling, it did not specifically respond to an argument that the statement was not hearsay because it was a command, instead ruling that it was irrelevant whether it was made in Defendant Bradsher’s official capacity and that it was not subject to a business record exception. “[Our] Court[s] ha[ve] long held that where a theory argued on appeal was not raised before the trial court, ‘the law does not permit parties to swap horses between courts in order to get a better mount . . . .” State v. Sharpe, 344 N.C. 190 , 473 S.E.2d 3 (1996) (citation

2020Finally, although the trial court made a thorough ruling, it did not specifically respond to an argument that the statement was not hearsay because it was a command, instead ruling that it was irrelevant whether it was made in Defendant Bradsher’s official capacity and that it was not subject to a business record exception. “[Our] Court[s] ha[ve] long held that where a theory argued on appeal was not raised before the trial court, ‘the law does not permit parties to swap horses between courts in order to get a better mount . . . .” State v. Sharpe, 344 N.C. 190 , 473 S.E.2d 3 (1996) (citation

22020–2020
In re: C.B., D.B. green
ncctapp · 2016
1 sentence

2025In re C.R.B., 245 N.C.

12025–2025
Cooper v. Commonwealth green
vactapp · 2009
2 sentences

2011While our appellate courts have not previously specifically ruled on whether information obtained from the NCIC database falls under the business record exception to the hearsay rule, the Virginia Court of Appeals addressed the issue in Cooper v. Commonwealth, 54 Va. App. 558 , 680 S.E.2d 361 (2009).

2011While our appellate courts have not previously specifically ruled on whether information obtained from the NCIC database falls under the business record exception to the hearsay rule, the Virginia Court of Appeals addressed the issue in Cooper v. Commonwealth, 54 Va. App. 558 , 680 S.E.2d 361 (2009).

12011–2011

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (6) NC § N.C. Gen. Stat. § 7B-101 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 127 (1973–2026) FL 46 (1985–2024) CT 45 (1983–2024) IL 42 (1977–2026) TX 39 (1989–2025) OH 36 (1990–2026) PA 33 (1986–2026) IN 32 (1982–2020) CA 31 (1963–2024) GA 28 (1983–2025) NJ 26 (1979–2025) MO 26 (1973–2024) WA 15 (2004–2022) MD 14 (1978–2023) VA 11 (2002–2023) AL 11 (1986–2016) MS 10 (1986–2019) LA 10 (1966–2014) MI 9 (1972–2026) NM 7 (2007–2019) NC 7 (2011–2025) ID 6 (1983–2009) UT 5 (1983–2020) HI 5 (2007–2019) ME 5 (1985–2020) TN 5 (1989–2016) SC 4 (1996–2022) MA 4 (1973–2025) DC 4 (1988–2010) IA 4 (1983–2024) CO 3 (1981–2021) OK 3 (1998–2010) ND 3 (1981–2007) NE 3 (2015–2026) OR 3 (2017–2023) WV 2 (1980–1980) VT 2 (2010–2011) AZ 2 (1973–2020) NV 2 (1988–1999) AK 2 (1978–2016) DE 2 (2022–2025) AR 2 (1997–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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