Chewning v. Commonwealth of Virginia, No. 2204-12-4, 2014 WL 931053 (Va. Ct. App. Mar. 11, 2014) (unpublished)

Key Insight: Trial court did not err in admitting cell phone records or the content of text messages exchanged between Chewning and girlfriend (who pleaded guilty to murdering her mother) on the day of murder, as records were admissible as computer-generated records not requiring hearsay analysis, and, alternatively, as hearsay admissible under business records exception, text messages were admissible under exception for party and adoptive admissions, and authentication of records and texts was achieved through testimony of Verizon Wireless records custodian; further, court did not err in permitting prosecutor and detective to read aloud certain portions of texts during trial or in permitting the limited interpretation of abbreviations and misspellings provided by the readers

Nature of Case: Criminal

Electronic Data Involved: Cell phone records, text messages