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object to it as no prejudice shown – officer also testified to what defendant said. Legan v. State, 289 Ga.App. 244, 656 S.E.2d 879 (January 18, 2008). Trial counsel properly prohibited cross- examination of officer as to description of perpetrator given by eyewitness to another officer and contained in police report. “The trial court allowed Detective Paradowski to testify as to the fact that he had read reports written by two other officers, but would not allow him to be cross-examined as to the contents of those reports, finding that such testimony would constitute hearsay. … In light of the general rule that police reports do not fall within any exception to the hearsay rule ( Brown v. State, 274 Ga. 31, 33-34 (549 S.E.2d 107) (2001)), we find that the trial court’s exclusion of this testimony did not constitute an abuse of discretion.” Moore v. State, 280 Ga.App. 894, 635 S.E.2d 253 (August 2, 2006). “Moore complains that his rights under the Confrontation Clause of the Sixth Amendment were violated by the admission of testimony by one of the investigators that he had run a computer check on the license plate of the Ford Taurus that Moore had driven onto the premises and determined that the car had been reported stolen. Introduction of evidence of the stolen-car report did not implicate the concerns of the Confrontation Clause, because it would appear that the primary purpose of the report was to advise law enforcement authorities of a crime in progress rather than to initiate a prosecution; therefore, the report was not testimonial in nature. See generally Pitts v. State, 280 Ga. 288 (627 S.E.2d 17) (2006). And even though evidence such as this is hearsay, it has been found to be admissible. See Russell v. State, 236 Ga.App. 645, 650(4) (512 S.E.2d 913) (1999).” Cox v. State, 263 Ga.App. 266, 587 S.E.2d 205 (September 3, 2003). Even if admission of police report narrative was error, “where the narrative of the police report is consistent with not only the officer’s testimony but also with that of the defendant, we will not reverse a conviction on the basis of a ‘continuing witness’ objection.” Evans v. State, 253 Ga.App. 71, 558 S.E.2d 51 (December 14, 2001). Trial court admitted an officer’s police report into evidence after the officer was cross-examined. The report contained facts consistent with the officer’s trial testimony and omits other facts to which she testified at trial. Defendant’s cross-examination of the officer made the contents of the report relevant for the jury’s consideration. Because the officer testified and was subject to cross-examination, the report was not hearsay. The State was entitled to rehabilitate the officer on redirect through proof of the prior consistent statements in the report because Defendant called into question whether the officer’s trial testimony was the result of recent fabrication in order to “carry the day” and secure a DUI conviction. Further, the report was admissible as a prior inconsistent statement as it would go to impeach the officer’s allegedly fabricated trial testimony. Brown v. State, 274 Ga. 31, 549 S.E.2d 107 (July 2, 2001). Held, the narratives contained in police reports generated in connection with police investigations are not the appropriate subject of a business record exception to the hearsay rule. Unlike the business world where objective information may be gathered in the stream of commerce, police work is often heavily influenced by the beliefs, impressions, and, at times, hunches of the investigating officer. Therefore, it is error for a trial court to allow a police officer to read into evidence the narrative portion of a police report of which he has no personal knowledge and does not prepare. This case therefore overrules a long list of cases. See also Horner v. State , 257 Ga.App. 12, 570 S.E.2d 94 (Aug. 9, 2002) (holding that police reports that do not contain narrative material may be admissible under the business record exception to hearsay). See also Williams v. State , 261 Ga.App. 410, 582 S.E.2d 556 (May 27, 2003) (Allowing an officer to read into the record a narrative from a police report on a similar transaction, as a business record, was error, but harmless because cumulative of other witnesses’ testimony; but query, couldn’t the officer read at least portions of the document as past recollection recorded without the document going to the jury? See OCGA § 24-9-69; Platt v. Nat’l General Ins. Co. , 205 Ga.App. 705, 423 S.E.2d 387 (1992)). Beckett v. Monroe, 249 Ga.App. 615, 548 S.E.2d 131 (April 30, 2001). A police sketch or diagram of an auto accident is not a police report with statements and opinions and therefore is admissible through a witness who testifies the drawing is substantially accurate, even though the drawing was not prepared by the witness or the author is unknown. PPPP. POLYGRAPH RESULTS Thomas v. State, 330 Ga.App. 67, 766 S.E.2d 527 (November 21, 2014). Physical precedent only. Convictions for sexual battery of a child affirmed; no error “in admitting the results of [defendant’s] police-administered polygraph examination.” 1. Defendant here stipulated to admission of the test results, and contrary to his argument, the stipulation wasn’t made ambiguous because the case number or court name of his indictment (which hadn’t happened yet) wasn’t written on the form. “Under Georgia law, … a stipulation as to the admissibility of polygraph exams is not
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