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Brown v. State

Police report narratives are not admissible under the business records exception to the hearsay rule because they do not have the inherent reliability of other traditional business records.

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On January 27, 1996, an anonymous informant called 911 and reported that a black male in a purple hat, black leather coat, and blue jeans was dealing drugs from a white automobile in an apartment complex. An officer dispatched to the site in response to the 911 call testified that he saw a man meeting the description standing next to a white car. The officer detained the man, later identified as appellant Fred Brown, based on the description.

A second officer dispatched to the scene found 58 hits of crack cocaine in plain view on the back seat of the white car. Through the car’s license tag, the second officer learned that the car was registered to appellant. The car was inoperable, with one of its back windows broken out, and had been sitting in the parking lot for over a year. Appellant was indicted for possession of cocaine with intent to distribute.

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