Admissibility of Evidence - Admissibility of Audio and Visual Recordings - Foundation for Admission of Recordings
Sound recordings of relevant events are admissible in evidence as long as a proper foundation is laid. In People v. Ely,[1] the Court of Appeals held that there are four different ways to authenticate sound recordings of conversations and noted that admissibility of a tape-recorded conversation requires proof of the accuracy or authenticity of the tape by "clear and convincing evidence" establishing that the offered evidence is genuine and that there has been no tampering with it.
The necessary foundation for the admissibility of sound recordings may be provided by (1) Testimony of a participant in the conversation that it is a complete and accurate reproduction of the conversation and has not been altered; (2) Testimony of a witness to the conversation or to its recording, such as the machine operator, that it is a complete and accurate reproduction of the conversation and has not been altered; (3) Testimony of a participant in the conversation together with proof by an expert witness that after analysis of the tapes for splices or alterations there was, in his or her opinion, no indication of either; or (4) A chain of custody method which requires, in addition to evidence concerning the making of the tapes and identification of the speakers, that within reasonable limits those who have handled the tape from its making to its production in court identify it and testify to its custody and unchanged condition. The fourth method may be used when no auditor of the conversation is available.[2]
The foundation for sound recording requires a showing that the entire tape is complete, accurate and free from alteration. These requirements cannot be avoided by introducing only isolated portions of tape to prove a particular prior inconsistent statement of a witness who testifies at trial.[3] The Court of Appeals has held that "identity and authenticity are separate facets of the required foundation, both of which must be established. The predicate for admission of tape recordings in evidence is clear and convincing proof that the tapes are genuine and that they have not been altered. This predicate is not satisfied where there is no attempt to offer proof about who recorded the conversation, how it was recorded (e.g., the equipment used) or the chain of custody during the years that elapsed between the time the conversation allegedly took place, and the trial.[4]
Relevant videotapes and technologically generated documentation are ordinarily admissible in evidence. Some reliable authentication and foundation, including technically acceptable self-authentication techniques, are necessary. Testimony, expert or otherwise, may also establish that a videotape truly and accurately represents what was before the camera. [5] Evidence establishing the chain of custody of the videotape may additionally buttress its authenticity and integrity and even allow for acceptable inferences of reasonable accuracy and freedom from tampering.[6] These methods of authentication are not exclusive and they correspond with standards developed and utilized in other States. [7] A video may be authenticated by a person other than the creator of the video where the testimony of a witness to the recorded events demonstrates that the videotape accurately represents the subject matter depicted.[8]
Exclusion is required if a sound recording "is so inaudible and indistinct that a jury must speculate as to its contents.[9] "The test of the sufficiency of a recording with respect to audibility is whether an "independent third [party] can listen to [the recording] and produce a reasonable transcript.” [10] If the overall tape is sufficiently audible, fair and accurate as to material events recorded thereon, the presence of some inaudible portions will not preclude its admissibility.[11] Such infirmities "go to the weight of the evidence, not its admissibility.[12]Identification of the voices on the tape is another condition to the admissibility of a sound recording. A witness may testify that he recognized a person's voice as being that of the defendant's husband, whether he heard it in person, over the telephone, or by some other mechanical or electronic means. The Court of Appeals has held that a voice heard "may be compared with the voice of a speaker whom one meets for the first time thereafter as well as with the voice of a speaker whom one has known before.” [13] This principle has been extended to voices on tape recordings. In ascertaining the identity of the voice on a tape "[t]he remoteness of the personal conversations between the identifying witness and defendant from the time of the voice identification affected the weight rather than the competency of the evidence".[14]
A telephone caller's identity may also be established, circumstantially, by the substance of the conversation, for example, where the caller refers to matters that only a particular person could have known about.[15]
When a witness testifies to the identity of a person to whom he has placed a call, he may be able to make the identification on the basis of familiarity with the recipient's voice.[16]
Even if the witness has no familiarity with the recipient's voice, identification may be made on the basis of circumstantial evidence. In People v. Lynes the court stated: "Thus, in part on the theory that the customary mode of operation of telephone users provides some assurance of reliability, in some instances the placing of a call to a number listed in a directory or other similarly responsible index of subscribers, coupled with an unforced acknowledgment by the one answering that he or she is the one so listed, has been held to constitute an adequate showing”.[17]
If an audio recording is admissible, the court will allow a jury to look at a transcript of the recording while listening to it. "A jury may use a transcript as an aid to understanding a tape recorded conversation when there is sufficient proof as to the accuracy of the transcript”.[18] The transcript is considered a form of demonstrative evidence which "illustrates" the recording.[19]
[1] 68 N.Y.2d 520, 510 N.Y.S.2d 532, 503 N.E.2d 88 (1986).
[2] People v. Ely, 68 N.Y.2d 520, 510 N.Y.S.2d 532, 503 N.E.2d 88 (1986).
[3] People v. Joyner, 240 A.D.2d 282, 660 N.Y.S.2d 398 (1st Dep't 1997).
In Matter of Giresi-Palazzolo v Palazzolo, 127 A.D.3d 752, 7 N.Y.S.3d 222 (2d Dept., 2015), the Appellate Division affirmed an order which denied the mother's family offense petition against the father and dismissed the proceeding. It held, inter alia, that contrary to the mother's contention, the Family Court did not err by admitting into evidence an audio recording of a conversation that took place between the parties on December 23, 2012. The father testified that he had personally recorded the conversation, that the recording was a complete and accurate reproduction of their interaction, and that the recording had not been altered. This testimony, which the Family Court credited, constituted sufficient proof of the accuracy and authenticity of the recording to warrant its admission. Any infirmities concerning audibility went to the weight of the evidence, not its admissibility (see People v. Ely, 68 N.Y.2d at 528; People v. McGee, 49 N.Y.2d at 60).
[4] In Grucci v Grucci, 20 N.Y.3d 893, 957 N.Y.S.2d 652 (2012) a civil action to recover damages for malicious prosecution, the plaintiff sought, through the testimony of his brother, Anthony Grucci, to play for the jury an audiotape of a telephone conversation in which the former wife Christine purportedly made clear to Anthony, at some point after she went to the police, that she was not afraid of Michael. Michael's attorney sought to play the audiotape during Anthony's testimony "as part of [his] presentation of [the telephone] conversation" with Christine that Anthony was recounting. Christine's attorney objected to the audiotape's admission on the grounds it was unreliable, "pieced together from a number of things" and "unintelligible"; that no chain of custody had been established; and generally that "no foundation [had been] laid for it at [that] point.” In response, Michael's attorney offered only to have Anthony identify the voices on the tape and state "whether or not the tape recording [was] fair and accurate." When the judge asked if the tape had been authenticated, Michael's attorney responded "Not yet; this witness will authenticate." The judge then sustained the objection, and Michael's attorney stated that he had no further questions for Anthony. The Court of Appeals observed that while a party to a taped conversation can identify the speakers, "identity and authenticity are separate facets of the required foundation, both of which must be established" ( People v. Ely, 68 N.Y.2d 520, 528 [1986] ). The Court of Appeals stated: "The predicate for admission of tape recordings in evidence is clear and convincing proof that the tapes are genuine and that they have not been altered.” Here, there was no attempt to offer proof about who recorded the conversation, how it was recorded (e.g., the equipment used) or the chain of custody during the nearly nine years that elapsed between early 2000, when the conversation allegedly took place, and the trial in late 2008. It held that given the facts and circumstances of this case, the judge did not abuse his discretion by requiring more than Anthony's representation that the tape was "fair and accurate" to establish a sufficient "predicate" before playing the tape for the jury.
[5] People v Byrnes, 33 NY2d 343, at 349.
[6] People v. Patterson, 93 N.Y.2d 80, 84©85, 710 N.E.2d 665 (1999) citing People v Ely, 68 NY2d 520, 527-528.
[7] See, e.g., Matter of Burack, 201 AD2d 561; People v Scutt, 254 AD2d 807, lv denied 92 NY2d 1038; People v Fondal, 154 AD2d 476, lv denied 75 NY2d 770; People v Higgins, 89 Misc 2d 913.
[8] People v. Patterson, 93 N.Y.2d 80, 84, 688 N.Y.S.2d 101, 710 N.E.2d 665; see Zegarelli v. Hughes, 3 N.Y.3d 64, 69, 781 N.Y.S.2d 488, 814 N.E.2d 795; Read v. Ellenville Natl. Bank, 20 A.D.3d 408, 409, 799 N.Y.S.2d 78.
In Matter of Blair v DiGregorio, 17 N.Y.S.3d 543, 2015 N.Y. Slip Op. 07383 (4th Dept., 2015) the Appellate Division, agreed with the father that Family Court erred in not admitting in evidence a video depicting the child in a vehicle with the mother on the ground that only the creator of that video could lay a proper foundation for its admission in evidence. During her testimony, the mother denied recording the video and testified that her older son recorded it. The father sought to introduce the video, which was sent by the mother to the father’s cell phone, to show that the mother was engaged in distracted driving by taking a video of the child while she was driving the vehicle. The father also sought to introduce that video to show that the mother was not a credible witness because the video supported the father’s assertion that the mother recorded the video, not her older son. The Appellate Division held that a video may be authenticated by a person other than the creator of the video where “the testimony of a witness to the recorded events demonstrates that the videotape accurately represents the subject matter depicted” and thus the court erred in not admitting he video in evidence on the ground that the mother did not record it. However, the error was harmless. Inasmuch as the father watched the video and testified to its contents. The admission of the video would have been cumulative of the testimony adduced at trial.
[9] People v. Carrasco, 125 A.D.2d 695, 696, 509 N.Y.S.2d 879, 881 (2d Dep't 1986); People v. Harris, 199 A.D.2d 636, 636, 604 N.Y.S.2d 1005, 1006 (3d Dep't 1993).
[10] People v. Carrasco, supra.
[11] See, e.g., People v. Morgan, 175 A.D.2d 930, 932, 573 N.Y.S.2d 765, 767 (2d Dep't 1991); People v. Harris, 199 A.D.2d 636, 636, 604 N.Y.S.2d 1005, 1006 (3d Dep't 1993).
[12] People v. McGee, 49 N.Y.2d 48, 60, 424 N.Y.S.2d 157, 164, 399 N.E.2d 1177, 1183 (1979); People v. Wilson, 207 A.D.2d 463, 463, 615 N.Y.S.2d 769, 770 (2d Dep't 1994).
[13] People v. Dunbar Contracting Co., 215 N.Y. 416, 422, 109 N.E. 554, 556 (1915).
[14] People v. Dinan, 15 A.D.2d 786, 787, 224 N.Y.S.2d 624, 627 (2d Dep't), aff'd, 11 N.Y.2d 350, 229 N.Y.S.2d 406, 183 N.E.2d 689 (1962).
[15] People v. Lynes, 49 N.Y.2d 286, 292, 425 N.Y.S.2d 295, 298, 401 N.E.2d 405, 408 (1980). Dobbin v. Greiner, 249 F. Supp. 2d 241 (S.D. N.Y. 2002).
[16] People v. Dunbar, 215 N.Y. 416, 422, 109 N.E. 554, 555 (1915). See also People v. McDermott, 160 Misc.2d 769, 773, 610 N.Y.S.2d 984, 986 (Dist. Ct. Nassau Co.1994) ("If the witness was not acquainted with the speaker, and, therefore, did not recognize his voice at the time of the telephone conversation, the telephone conversation is admissible if the witness testifies that she met the speaker thereafter and then recognized his voice as the voice she had heard over the telephone").
[17] People v. Lynes, 49 N.Y.2d 286, 425 N.Y.S.2d 295, 401 N.E.2d 405 (1980).
[18] People v. Tapia, 114 A.D.2d 983, 984, 495 N.Y.S.2d 93, 94 (2d Dep't 1985).
[19] People v. Feld, 305 N.Y. 322, 331-32, 113 N.E.2d 440, 444 (1953). See also People v. Robinson, 158 A.D.2d 628, 629, 551 N.Y.S.2d 599, 599 (2d Dep't 1990) (court instructed the jury that the transcripts were not in evidence but were for their assistance only).
Sound recordings of relevant events are admissible in evidence as long as a proper foundation is laid. In People v. Ely,[1] the Court of Appeals held that there are four different ways to authenticate sound recordings of conversations and noted that admissibility of a tape-recorded conversation requires proof of the accuracy or authenticity of the tape by "clear and convincing evidence" establishing that the offered evidence is genuine and that there has been no tampering with it.
The necessary foundation for the admissibility of sound recordings may be provided by (1) Testimony of a participant in the conversation that it is a complete and accurate reproduction of the conversation and has not been altered; (2) Testimony of a witness to the conversation or to its recording, such as the machine operator, that it is a complete and accurate reproduction of the conversation and has not been altered; (3) Testimony of a participant in the conversation together with proof by an expert witness that after analysis of the tapes for splices or alterations there was, in his or her opinion, no indication of either; or (4) A chain of custody method which requires, in addition to evidence concerning the making of the tapes and identification of the speakers, that within reasonable limits those who have handled the tape from its making to its production in court identify it and testify to its custody and unchanged condition. The fourth method may be used when no auditor of the conversation is available.[2]
The foundation for sound recording requires a showing that the entire tape is complete, accurate and free from alteration. These requirements cannot be avoided by introducing only isolated portions of tape to prove a particular prior inconsistent statement of a witness who testifies at trial.[3] The Court of Appeals has held that "identity and authenticity are separate facets of the required foundation, both of which must be established. The predicate for admission of tape recordings in evidence is clear and convincing proof that the tapes are genuine and that they have not been altered. This predicate is not satisfied where there is no attempt to offer proof about who recorded the conversation, how it was recorded (e.g., the equipment used) or the chain of custody during the years that elapsed between the time the conversation allegedly took place, and the trial.[4]
Relevant videotapes and technologically generated documentation are ordinarily admissible in evidence. Some reliable authentication and foundation, including technically acceptable self-authentication techniques, are necessary. Testimony, expert or otherwise, may also establish that a videotape truly and accurately represents what was before the camera. [5] Evidence establishing the chain of custody of the videotape may additionally buttress its authenticity and integrity and even allow for acceptable inferences of reasonable accuracy and freedom from tampering.[6] These methods of authentication are not exclusive and they correspond with standards developed and utilized in other States. [7] A video may be authenticated by a person other than the creator of the video where the testimony of a witness to the recorded events demonstrates that the videotape accurately represents the subject matter depicted.[8]
Exclusion is required if a sound recording "is so inaudible and indistinct that a jury must speculate as to its contents.[9] "The test of the sufficiency of a recording with respect to audibility is whether an "independent third [party] can listen to [the recording] and produce a reasonable transcript.” [10] If the overall tape is sufficiently audible, fair and accurate as to material events recorded thereon, the presence of some inaudible portions will not preclude its admissibility.[11] Such infirmities "go to the weight of the evidence, not its admissibility.[12]Identification of the voices on the tape is another condition to the admissibility of a sound recording. A witness may testify that he recognized a person's voice as being that of the defendant's husband, whether he heard it in person, over the telephone, or by some other mechanical or electronic means. The Court of Appeals has held that a voice heard "may be compared with the voice of a speaker whom one meets for the first time thereafter as well as with the voice of a speaker whom one has known before.” [13] This principle has been extended to voices on tape recordings. In ascertaining the identity of the voice on a tape "[t]he remoteness of the personal conversations between the identifying witness and defendant from the time of the voice identification affected the weight rather than the competency of the evidence".[14]
A telephone caller's identity may also be established, circumstantially, by the substance of the conversation, for example, where the caller refers to matters that only a particular person could have known about.[15]
When a witness testifies to the identity of a person to whom he has placed a call, he may be able to make the identification on the basis of familiarity with the recipient's voice.[16]
Even if the witness has no familiarity with the recipient's voice, identification may be made on the basis of circumstantial evidence. In People v. Lynes the court stated: "Thus, in part on the theory that the customary mode of operation of telephone users provides some assurance of reliability, in some instances the placing of a call to a number listed in a directory or other similarly responsible index of subscribers, coupled with an unforced acknowledgment by the one answering that he or she is the one so listed, has been held to constitute an adequate showing”.[17]
If an audio recording is admissible, the court will allow a jury to look at a transcript of the recording while listening to it. "A jury may use a transcript as an aid to understanding a tape recorded conversation when there is sufficient proof as to the accuracy of the transcript”.[18] The transcript is considered a form of demonstrative evidence which "illustrates" the recording.[19]
[1] 68 N.Y.2d 520, 510 N.Y.S.2d 532, 503 N.E.2d 88 (1986).
[2] People v. Ely, 68 N.Y.2d 520, 510 N.Y.S.2d 532, 503 N.E.2d 88 (1986).
[3] People v. Joyner, 240 A.D.2d 282, 660 N.Y.S.2d 398 (1st Dep't 1997).
In Matter of Giresi-Palazzolo v Palazzolo, 127 A.D.3d 752, 7 N.Y.S.3d 222 (2d Dept., 2015), the Appellate Division affirmed an order which denied the mother's family offense petition against the father and dismissed the proceeding. It held, inter alia, that contrary to the mother's contention, the Family Court did not err by admitting into evidence an audio recording of a conversation that took place between the parties on December 23, 2012. The father testified that he had personally recorded the conversation, that the recording was a complete and accurate reproduction of their interaction, and that the recording had not been altered. This testimony, which the Family Court credited, constituted sufficient proof of the accuracy and authenticity of the recording to warrant its admission. Any infirmities concerning audibility went to the weight of the evidence, not its admissibility (see People v. Ely, 68 N.Y.2d at 528; People v. McGee, 49 N.Y.2d at 60).
[4] In Grucci v Grucci, 20 N.Y.3d 893, 957 N.Y.S.2d 652 (2012) a civil action to recover damages for malicious prosecution, the plaintiff sought, through the testimony of his brother, Anthony Grucci, to play for the jury an audiotape of a telephone conversation in which the former wife Christine purportedly made clear to Anthony, at some point after she went to the police, that she was not afraid of Michael. Michael's attorney sought to play the audiotape during Anthony's testimony "as part of [his] presentation of [the telephone] conversation" with Christine that Anthony was recounting. Christine's attorney objected to the audiotape's admission on the grounds it was unreliable, "pieced together from a number of things" and "unintelligible"; that no chain of custody had been established; and generally that "no foundation [had been] laid for it at [that] point.” In response, Michael's attorney offered only to have Anthony identify the voices on the tape and state "whether or not the tape recording [was] fair and accurate." When the judge asked if the tape had been authenticated, Michael's attorney responded "Not yet; this witness will authenticate." The judge then sustained the objection, and Michael's attorney stated that he had no further questions for Anthony. The Court of Appeals observed that while a party to a taped conversation can identify the speakers, "identity and authenticity are separate facets of the required foundation, both of which must be established" ( People v. Ely, 68 N.Y.2d 520, 528 [1986] ). The Court of Appeals stated: "The predicate for admission of tape recordings in evidence is clear and convincing proof that the tapes are genuine and that they have not been altered.” Here, there was no attempt to offer proof about who recorded the conversation, how it was recorded (e.g., the equipment used) or the chain of custody during the nearly nine years that elapsed between early 2000, when the conversation allegedly took place, and the trial in late 2008. It held that given the facts and circumstances of this case, the judge did not abuse his discretion by requiring more than Anthony's representation that the tape was "fair and accurate" to establish a sufficient "predicate" before playing the tape for the jury.
[5] People v Byrnes, 33 NY2d 343, at 349.
[6] People v. Patterson, 93 N.Y.2d 80, 84©85, 710 N.E.2d 665 (1999) citing People v Ely, 68 NY2d 520, 527-528.
[7] See, e.g., Matter of Burack, 201 AD2d 561; People v Scutt, 254 AD2d 807, lv denied 92 NY2d 1038; People v Fondal, 154 AD2d 476, lv denied 75 NY2d 770; People v Higgins, 89 Misc 2d 913.
[8] People v. Patterson, 93 N.Y.2d 80, 84, 688 N.Y.S.2d 101, 710 N.E.2d 665; see Zegarelli v. Hughes, 3 N.Y.3d 64, 69, 781 N.Y.S.2d 488, 814 N.E.2d 795; Read v. Ellenville Natl. Bank, 20 A.D.3d 408, 409, 799 N.Y.S.2d 78.
In Matter of Blair v DiGregorio, 17 N.Y.S.3d 543, 2015 N.Y. Slip Op. 07383 (4th Dept., 2015) the Appellate Division, agreed with the father that Family Court erred in not admitting in evidence a video depicting the child in a vehicle with the mother on the ground that only the creator of that video could lay a proper foundation for its admission in evidence. During her testimony, the mother denied recording the video and testified that her older son recorded it. The father sought to introduce the video, which was sent by the mother to the father’s cell phone, to show that the mother was engaged in distracted driving by taking a video of the child while she was driving the vehicle. The father also sought to introduce that video to show that the mother was not a credible witness because the video supported the father’s assertion that the mother recorded the video, not her older son. The Appellate Division held that a video may be authenticated by a person other than the creator of the video where “the testimony of a witness to the recorded events demonstrates that the videotape accurately represents the subject matter depicted” and thus the court erred in not admitting he video in evidence on the ground that the mother did not record it. However, the error was harmless. Inasmuch as the father watched the video and testified to its contents. The admission of the video would have been cumulative of the testimony adduced at trial.
[9] People v. Carrasco, 125 A.D.2d 695, 696, 509 N.Y.S.2d 879, 881 (2d Dep't 1986); People v. Harris, 199 A.D.2d 636, 636, 604 N.Y.S.2d 1005, 1006 (3d Dep't 1993).
[10] People v. Carrasco, supra.
[11] See, e.g., People v. Morgan, 175 A.D.2d 930, 932, 573 N.Y.S.2d 765, 767 (2d Dep't 1991); People v. Harris, 199 A.D.2d 636, 636, 604 N.Y.S.2d 1005, 1006 (3d Dep't 1993).
[12] People v. McGee, 49 N.Y.2d 48, 60, 424 N.Y.S.2d 157, 164, 399 N.E.2d 1177, 1183 (1979); People v. Wilson, 207 A.D.2d 463, 463, 615 N.Y.S.2d 769, 770 (2d Dep't 1994).
[13] People v. Dunbar Contracting Co., 215 N.Y. 416, 422, 109 N.E. 554, 556 (1915).
[14] People v. Dinan, 15 A.D.2d 786, 787, 224 N.Y.S.2d 624, 627 (2d Dep't), aff'd, 11 N.Y.2d 350, 229 N.Y.S.2d 406, 183 N.E.2d 689 (1962).
[15] People v. Lynes, 49 N.Y.2d 286, 292, 425 N.Y.S.2d 295, 298, 401 N.E.2d 405, 408 (1980). Dobbin v. Greiner, 249 F. Supp. 2d 241 (S.D. N.Y. 2002).
[16] People v. Dunbar, 215 N.Y. 416, 422, 109 N.E. 554, 555 (1915). See also People v. McDermott, 160 Misc.2d 769, 773, 610 N.Y.S.2d 984, 986 (Dist. Ct. Nassau Co.1994) ("If the witness was not acquainted with the speaker, and, therefore, did not recognize his voice at the time of the telephone conversation, the telephone conversation is admissible if the witness testifies that she met the speaker thereafter and then recognized his voice as the voice she had heard over the telephone").
[17] People v. Lynes, 49 N.Y.2d 286, 425 N.Y.S.2d 295, 401 N.E.2d 405 (1980).
[18] People v. Tapia, 114 A.D.2d 983, 984, 495 N.Y.S.2d 93, 94 (2d Dep't 1985).
[19] People v. Feld, 305 N.Y. 322, 331-32, 113 N.E.2d 440, 444 (1953). See also People v. Robinson, 158 A.D.2d 628, 629, 551 N.Y.S.2d 599, 599 (2d Dep't 1990) (court instructed the jury that the transcripts were not in evidence but were for their assistance only).
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