State v. Scott

The principal issue involved in this case is whether the rule of evidence, referred to as “past recollection recorded,” is recognized in Ohio, whether it may be employed in a criminal trial, and whether, if so employed, such rule is violative of a defendant’s Sixth Amendment right of confrontation, including the opportunity of cross-examination. Although such rule of evidence has been specifically approved by the highest courts of most of our sister states, it appears that this issue has not heretofore been directly passed upon by this court.

The problem of “past recollection recorded” arises…