State v. McGee

ARNOLD, Judge.

Defendant first contends that the court erred in admitting into evidence the magistrate’s order finding him in contempt of court because the document was not identified by a witness and no foundation was laid to establish its authenticity. We reject this contention. It is generally accepted that “[a] court will notice earlier proceedings in the same cause ...” 1 Brandis on North Carolina Evidence, § 13 (2d Rev. Ed. 1982). In addition, certain documentary evidence is admissible without authentication if it is inherently reliable. See In re Arthur, 27 N.C. App. 227, 218 S.E. 2d…