Crusoe v. Davis
Alabama Supreme Court
176 So. 3d 1200 (2015)

- Written by Sean Carroll, JD
Facts
Dorothy Crusoe (plaintiff) and Erica Boyd were in a car accident. Officer Donald Cartier responded to the accident and compiled a written report based on what Crusoe and Boyd told him. At trial, Crusoe called Cartier as a witness. Cartier could not remember the specifics of the accident, and viewing the accident report did not refresh his memory. As a result, Crusoe sought to have the accident report admitted into evidence as a past recollection recorded. The trial court excluded the report because Cartier did not witness the accident. Crusoe appealed.
Rule of Law
Issue
Holding and Reasoning (Moore, C.J.)
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