Is a statement made by a police officer on a body cam recording admissible as a public employee record?

California, United States of America


The following excerpt is from People v. R.C. (In re R.C.), 2d Juv. No. B301298 (Cal. App. 2020):

5. For the first time on appeal, appellant also contends the statement was admissible as a public employee record under Evidence Code section 1280. Appellant did not urge the court to admit the evidence on this ground, so his contention is forfeited. In any event, admitting the body cam recording or the transcript of that recording under the public records exception would not render the statements contained within that recording admissible for the truth of the matter asserted. For the statements to be admissible for that purpose, appellant had to establish a hearsay exception. (See People v. Sanchez (2016) 63 Cal.4th 665, 675 ["Multiple hearsay may not be admitted unless there is an exception for each level"].) Appellant did not do so here.

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