Hungerford v. State

Appellant, a department store employee, was convicted of grand theft. She argues that a log prepared daily by the store manager for the cash registers was not admissible in evidence as a business record under Crawford v. Washington, 541 U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004). We affirm.

Appellant was responsible for gathering money from each of the cash registers and preparing deposits. The document which is in dispute is known as an “over/short log,” and it is kept in the normal course of business by each store manager. The log is filled out every day by the store manager, and, when…