People v. Goldsmith
59 Cal. 4th 258
| Cal. | 2014Background
- Carmen Goldsmith was cited for running a red light at Centinela Ave. & Beach Ave., Inglewood, based on images and a 12-second video from the city’s automated traffic enforcement system (ATES).
- The ATES (operated by Inglewood PD, maintained by Redflex) produced three photos (previolation, postviolation, license plate) with an imprinted data bar (date, time, location, red-light duration) and a short video; an officer reviewed images before issuance of the citation.
- Investigator Dean Young (Inglewood PD) testified about the ATES operation, his monthly inspections of signals, timing checks showing a ~4-second yellow phase, and interpreted the photos/video to place Goldsmith in the intersection during the red phase.
- Goldsmith objected at trial to admission of the ATES evidence for lack of foundation and as hearsay; the traffic commissioner overruled objections, found Goldsmith guilty, and imposed a fine.
- On appeal and review, the central legal questions were (1) whether the ATES images/data were properly authenticated as admissible writings and (2) whether the machine‑generated images/data constituted hearsay (or implicated Confrontation Clause). The Supreme Court granted review and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authentication of ATES images/data | Young’s testimony plus statutory presumptions (§§1552–1553) sufficiently establish images are what prosecution claims | Prosecution needed additional foundational proof (e.g., Redflex technician, maintenance/calibration records) because digital images are easily manipulable | Court: Authentication satisfied by officer testimony and statutory presumptions; no special expert/technician required absent specific challenge to alteration |
| Hearsay status of machine‑generated images/data | ATES output is computer‑generated, not a human statement, so not hearsay; legislative amendments confirm non‑hearsay status | Data bar and printed information are hearsay statements (and don’t qualify for business/public‑records exceptions) | Court: Machine‑generated images/data are not hearsay under Evidence Code; admission did not implicate hearsay rules |
| Confrontation Clause challenge | Not raised as primary by People; if raised, would be satisfied because no testimonial human declarant — machine output cannot be cross‑examined | Admission of ATES output violates Confrontation Clause as testimonial evidence prepared for prosecution | Court: Confrontation Clause not implicated because machine outputs are not testimonial statements by a person; Lopez controls |
| Need for special evidentiary rules in red‑light camera cases | Standard evidentiary rules and existing presumptions suffice; traffic‑court informality doesn’t justify higher standard | Traffic‑court dynamics + contractor involvement (Redflex) warrant heightened foundation and scrutiny to protect defendants | Court: Declines to create special heightened requirement; ordinary authentication and admissibility standards apply |
Key Cases Cited
- People v. Gray, 58 Cal.4th 901 (Cal. 2014) (context on ATES statutory scheme and warnings)
- People v. Bowley, 59 Cal.2d 855 (Cal. 1963) (photographs as "silent witness" and substantive evidence)
- People v. Skiles, 51 Cal.4th 1178 (Cal. 2011) (authentication required for secondary evidence)
- People v. Gonzalez, 38 Cal.4th 932 (Cal. 2006) (fair and accurate representation as usual foundation for photographic evidence)
- People v. Lopez, 55 Cal.4th 569 (Cal. 2012) (machine‑generated printouts not Confrontation Clause statements)
- People v. Hawkins, 98 Cal.App.4th 1428 (Cal. Ct. App. 2002) (presumptions about computer print function accuracy)
- People v. McWhorter, 47 Cal.4th 318 (Cal. 2009) (distinguishing computer animations/enhanced images from straightforward machine outputs)