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Name: People v. Goldsmith
Case #: S201443
Court: CA Supreme Court
District CalSup
Opinion Date: 06/05/2014

Evidence recorded by traffic camera was properly admitted in prosecution for running a red light. Goldsmith was cited for failing to stop at a red light at an intersection in violation of Vehicle Code section 21453. She was found guilty of the infraction based on evidence of several photographs and a 12-second video generated by an automatic traffic enforcement system (ATES). The conviction was affirmed by the appellate division of the superior court and the Court of Appeal. The California Supreme Court granted review to consider Goldsmith’s claim that the trial court improperly admitted the ATES evidence over her hearsay and inadequate foundation objections. Held: Affirmed. The police investigator’s testimony adequately established that the ATES photographs were from the relevant intersection. The photographs depicted Goldsmith at the intersection, which supported a finding that the photos were authentic. There was no evidence that the ATES evidence was materially altered or edited. The court declined to require a greater showing of authentication for the admissibility of digital images merely because in theory they could be manipulated. It also rejected Goldsmith’s argument that the ATES evidence constituted inadmissable hearsay.