Citation Edit

City of Seattle v. Heath, 10 Wash. App. 949, 520 P.2d 1392 (1974) (full-text).

Factual Background Edit

The defendant was convicted of negligent driving, leaving the scene of an accident, and driving without a license. He appealed.

Appellate Court Proceedings Edit

He claimed that the trial court erred in admitting computer abstracts of his driving record and the status of his driver's license. The defendant claimed that there was no proper foundation laid for admission of the evidence under Washington Revised Code 5.45.020.

At trial, the assistant director of the traffic violations bureau of the municipal court had testified that his office had a direct terminal to the Department of Motor Vehicles computer. He testified as to how the information was prepared by the Department of Motor Vehicles' computer and then sent to his office. He further testified that the information was entered into the computer at the time it was received by the Department of Motor Vehicles.

The appellate court first noted that, unless there was a manifest abuse of discretion, the trial judge's ruling admitting or excluding the records would not be disturbed. Here, it was established that the witness was a custodian of the bureau's records, and a qualified witness insofar as he testified to the method of preparation of the abstracts. In addition, the abstracts were clearly made during the regular course of business. In the absence of any abuse of discretion, the trial judgment was affirmed.

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