Is Testimony About Computer Display Hearsay ?

In Penny v. Commonwealth, 6 Va. App. 494, 370 S.E.2d 314 (1988), the Court did not rule that testimony concerning a computer display was not hearsay. The contention was made by Penny that the trial judge "erred in admitting the telephone company records without the proper foundation." Id. at 496, 370 S.E.2d at 316. In response, the Commonwealth argued that the records were admissible as an exception to the hearsay rule. See Penny, 6 Va. App. at 496-98, 370 S.E.2d at 315-17. The Court merely said "we do not believe that the admissibility of computer-generated displays . . . should be resolved solely by resort to traditional hearsay analysis." Id. at 497, 370 S.E.2d at 316. In response to the parties' arguments, we held "that the call trap results may be admitted only after the particular device in question has been proven reliable." Id. at 499, 370 S.E.2d at 317.