Holcomb v. State

RODOWSKY, Judge.

In this prosecution for murder the trial court admitted as a business record a contemporaneous memorandum, prepared by a police officer but not signed by the accused, which contained the accused’s oral confession. We granted certiorari primarily to decide whether the State was required to prove that the accused had acknowledged the accuracy of the document’s content. The State was not so required, as explained below.

On October 21, 1982, Tanea M. Rothschild, age 35, was found dead in her apartment in Baltimore County. She had been strangled and repeatedly stabbed. The next day…