Simms v. Dixon
District of Columbia Court of Appeals
291 A.2d 184 (D.C. App. 1972)
Relevant factsFree
After a car accident with conflicting accounts of how the collision occurred, Simms (plaintiff) sought to introduce photos of her damaged car to show the point of impact, offering to lay the foundation through her own testimony, but the trial court refused to admit the photos without the photographer's testimony, and Simms lost at trial.
IssueFree
Whether the foundation for admitting photographs may be laid by any witness who can testify the photographs accurately represent the facts they depict.