State v. Smith (1975)

In State v. Smith, 85 Wn.2d 840, 540 P.2d 424 (Wash. 1975), the Washington Supreme Court held that a party must satisfy seven factors in order to establish authenticity of an audiotape: (1) It must be shown that the mechanical transcription device was capable of taking testimony. (2) It must be shown that the operator of the device was competent to operate it. (3) The authenticity and correctness of the recording must be established. (4) It must be shown that changes, additions, or deletions have not been made. (5) The manner of preservation of the record must be shown. (6) Speakers must be identified. (7) It must be shown that the testimony elicited was freely and voluntarily made, without any kind of duress. (Id. at 428.)