State v. Acquisto

Edward Acquisto (defendant), charged with sexual assault, presented an alibi that he was home with his mother Griffin at the time, and Griffin and coworker Callahan testified they'd been unable to work that day due to a strike; the prosecution introduced payroll records, authenticated by department records custodian Marie, showing Griffin and Callahan had actually worked that day and that the strike occurred on different dates. Acquisto objected to the records as hearsay, arguing the common-law rule required testimony from every individual who participated in creating them; the trial court admitted the records and convicted Acquisto, and he appealed.