Michael Dewayne Norris v. the State of Texas

Summary

The Eleventh Court of Appeals of Texas affirmed Michael Dewayne Norris’s conviction for assault of a public servant and his twenty-year sentence. The court held that body-camera footage recording jail security footage was an admissible duplicate under Texas Rule of Evidence 1003 because Norris did not challenge the original video’s authenticity and the circumstances did not make admission unfair.

Holdings

1. The body-camera footage was an admissible duplicate of the original jail security video because the appellant did not challenge the authenticity of the original and the circumstances did not make admission of the duplicate unfair.
2. The trial court did not abuse its discretion by admitting the body-camera footage, and the appellate court overruled Norris's sole issue.

Questions Presented

1. Whether the trial court abused its discretion by admitting body-camera footage recording the original jail security video when the appellant objected that the original was required under the best evidence rule.

Disposition

affirmed