United States v. Taylor
United States Court of Appeals for the Fifth Circuit
530 F.2d 639 (5th Cir. 1976)
James Hicks and Freddie Taylor (defendants) robbed a bank and locked everyone else inside the vault. A bank camera, activated after they left the tellers' area, photographed Hicks and Taylor inside the bank. At trial, the defendants objected that no witness could testify the photos accurately depicted the scene, since everyone who could have witnessed it firsthand was locked in the vault at the time. The prosecution instead offered testimony about how the film was installed and developed. The district court admitted the photographs, the defendants were convicted, and they appealed.
Whether photographs may be admissible as probative evidence, rather than solely as demonstrative evidence supporting a witness's testimony, if the photographing and reproduction process is shown to be reliable.