State of Missouri v. Terrill E. Reynolds, 456 S.W.3d 101

Early-morning taxi robbery: cab driver Kevin Dulle was robbed at gunpoint around 3:00 a.m. after picking up three passengers; the robber took $425 and fled.
The taxi company provided the phone number used to summon the cab; police called that number with no answer.
A few hours later police responded to a disturbance at an apartment on the same block where occupants reported a robbery and an argument about money; witnesses described the female participant wearing a pink hoodie and said Reynolds had a handgun.
Officers searched the apartment with consent, found money in unusual places, a magazine clip and a handgun, and recovered a cell phone from a bedroom dresser.
The cab driver identified Reynolds in a live lineup and at trial and identified the recovered handgun as the weapon used. Police took screenshots of the phone’s call log (incoming/missed calls) and introduced those screenshots at trial.
Reynolds was convicted of first-degree robbery, armed criminal action, and unlawful possession of a firearm; he appealed only the admission of the call-log screenshots as hearsay (and raised, but waived, a foundational-ownership argument).

Issue	Reynolds' Argument	State's Argument	Held
Admissibility of cell-phone call-log screenshots	Screenshots are hearsay and not admissible as business records	Call logs are computer-generated data, not human statements; officer personally examined phone and authenticated screenshots	Admission was not erroneous: call logs are non-hearsay computer-generated records when reliability is shown
Foundation/ownership of phone	Phone ownership not established, so screenshots lack foundation	Officer and witnesses tied phone to Reynolds (found in his room; he used it; cab company records matched number)	Foundation objection was waived on appeal (no contemporaneous trial objection); ownership evidence otherwise supported admissibility
Reliance on State v. Courtney	Courtney supports exclusion because it involved hearsay about call logs relayed by a third party	Courtney is distinguishable: in this case the officer personally examined and admitted the actual screenshots	Court rejected reliance on Courtney and found the situation analogous to Dunn
Prejudice from admission even if error	Admission was outcome-determinative and requires reversal	Even without screenshots, strong independent evidence (identifications, gun, witnesses) supported conviction	Any error would be harmless; admission was not prejudicial

State v. Dunn, 7 S.W.3d 427 (Mo. App. 1999) (computer-generated records are not hearsay; admissibility depends on reliability of the process)
State v. Courtney, 258 S.W.3d 117 (Mo. App. 2008) (distinguishes hearsay problems where an officer reports call-log information received from a third party rather than examining the device)
State v. Sutherland, 939 S.W.2d 373 (Mo. banc 1997) (definition of hearsay)
State v. Forrest, 183 S.W.3d 218 (Mo. banc 2006) (standard for abuse of discretion in evidentiary rulings)
State v. Berwald, 186 S.W.3d 349 (Mo. App. 2005) (improper admission in criminal cases is reversible only if outcome-determinative)
State v. Black, 50 S.W.3d 778 (Mo. banc 2001) (prejudice test for erroneously admitted evidence)