Admission of Video Evidence In North Carolina

In State v. Cannon, 92 N.C. App. 246, 374 S.E.2d 604, 608 (1988), this Court discussed how to lay a proper foundation for the admission of videotape evidence. The prerequisite that the offeror lay a proper foundation for the videotape can be met by: (1) testimony that the motion picture or videotape fairly and accurately illustrates the events filmed (illustrative purposes); (2) "proper testimony concerning the checking and operation of the video camera and the chain of evidence concerning the videotape . . ."; (3) testimony that "the photographs introduced at trial were the same as those [the witness] had inspected immediately after processing," (substantive purposes); or (4) "testimony that the videotape had not been edited, and that the picture fairly and accurately recorded the actual appearance of the area 'photographed.'" Cannon, 92 N.C. App. at 254, 374 S.E.2d at 608-09.