Baker (defendant) was charged with murder and robbery and sought to introduce evidence that the police had brought one of the victims to where Baker was being held and that the victim had said that Baker was not one of the people who attacked and robbed him. Baker sought to elicit testimony about this confrontation from Officer Bolton who was present at the time, but could not remember what occurred. As a result, Baker instead sought to introduce a police report that captured the confrontation to help refresh Bolton’s memory. The report was written by another officer. The trial court refused to allow Baker to so refresh Bolton’s memory on the grounds that he did not write the police report. Baker was then convicted and she appealed.