People v. Skiles, 126 Cal. Rptr. 3d 456

Defendant was convicted of residential burglary and receiving stolen property in California; the prior Alabama manslaughter conviction was challenged under Three Strikes as a serious felony.
Prosecution submitted certified Alabama court records (exhibits 16-17) to prove the prior conviction; these did not describe all charged conduct.
During noon recess, a clerk faxed a certified copy of the first page of the indictment (exhibit 18) describing manslaughter by red light, driving into the victim, and death; defense objected to it as photocopy.
Trial court admitted exhibit 18; sentencing found that defendant personally inflicted great bodily injury during the Alabama offense, making it a strike.
Court of Appeal affirmed admission of exhibit 18, relying on Evidence Code section 1521 and authentication by comparing with exhibit 16.
California Supreme Court granted review to decide if a faxed copy of a certified court record is admissible as secondary evidence to prove a prior conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a faxed copy of a certified court record can be admitted as secondary evidence to prove a prior conviction	People argued 1521 allows admissible secondary evidence with authentication; faxed copy may be admissible with sufficient evidence.	Skiles argued a faxed copy lacks proper certification under 1530 and is inadmissible per se.	Faxed copies may be admissible with authentication; not per se inadmissible.
Whether section 1530 requires original certification for admissibility of copies of official records	Certified copies are prima facie evidence and presumptively reliable.	A faxed copy lacks the original certification and should be excluded.	Certification provides prima facie evidence; alternatives may authenticate with other evidence.
Whether the prosecution met authenticity burden for exhibit 18 through other evidence besides the fax	Exhibit 18 corroborated by exhibits 16-17 and grand jury true bill; contents align.	Reliability hinges on the faxed copy alone; insufficient without original certification.	Prosecution provided substantial authenticating evidence; secondary evidence rule satisfied.
Did admission of exhibit 18 violate defendant's confrontation rights	Not properly raised; later no objection on confrontation grounds.	Admission of a photocopy could infringe confrontation; raised at trial.	Constitutional claim forfeited; not decided on the merits.

People v. Atkins, 210 Cal.App.3d 47 (1989) (copy of certification admissible if authenticity not in dispute)
People v. Delgado, 43 Cal.4th 1059 (2008) (certified official records constitute prima facie evidence)
Ambriz v. Kelegian, 146 Cal.App.4th 1519 (2007) (presumptions and authentication of certified copies)
People v. Gibson, 90 Cal.App.4th 371 (2001) (means of authenticating a writing beyond code provisions)
People v. Tafoya, 42 Cal.4th 147 (2007) (confrontation claim forfeited when not raised at trial)
People v. Pieters, 52 Cal.3d 894 (1991) (statutory interpretation guiding evidence rules)