People v. Hauck

Defendant appealed his conviction for one count of drug-induced homicide and two counts of delivery of a controlled substance. He appealed arguing that the trial court erred when it allowed cell phone records into evidence under the business record exception to hearsay as self-authenticating records. The appellate court found the records did not comply with IRE 902(11) because they were not accompanied by a certification entered under oath, but affirmed on the basis that the evidence was cumulative and their admission was harmless. (ZENOFF and SCHOSTOK, concurring)