Is a police narrative report admissible into evidence in a motor vehicle case?

California, United States of America


The following excerpt is from Coombs v. Pierce, 1 Cal.App.4th 568, 2 Cal.Rptr.2d 249 (Cal. App. 1991):

While the officer's narrative report was admissible into evidence pursuant to Snelgrove v. Department of Motor Vehicles (1987) 194 Cal.App.3d 1364, 1374, 240 Cal.Rptr. 281, the mere attachment of a photocopy of the test result lacks evidentiary foundation to support any fact to be derived from that attachment.

"When an administrative agency initiates an action to suspend or revoke a license, the burden of proving the facts necessary to support the action rests with the agency making the allegation." (Daniels v. Department of Motor Vehicles, supra, 33 Cal.3d 532, 536, 189 Cal.Rptr. 512, 658 P.2d 1313.)

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