State v. Blue, 547 P.3d 167

Vanessa Blue was convicted of two counts of unauthorized use of a vehicle (UUV) for her extended use of a rented U-Haul truck beyond the contract period.
Blue denied signing the rental contract and objected to the admission of a photograph of the rental contract as evidence, arguing that only the original contract should be admitted under the best evidence rule (OEC 1002).
The trial court admitted the photograph as a "duplicate" under OEC 1003, over Blue's objections.
The photograph was sent by a U-Haul manager in Oregon after requesting it from an Albuquerque store, as the original signed contract was kept at the rental location.
On appeal, Blue argued that a genuine question of authenticity regarding the original contract required the state to offer the original rather than a photographic duplicate.
The appellate court reviewed whether the trial court erred in admitting the photograph, ultimately affirming the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a photograph of the signed contract admissible as a duplicate under OEC 1003?	No genuine authenticity question was raised—photograph is an admissible duplicate.	Defendant’s denial of signing creates a genuine question requiring the original.	Admissible—mere denial not enough to bar duplicate; no genuine authenticity question.
Does the best evidence rule (OEC 1002) require the original contract to be introduced in these circumstances?	No—exceptions allow duplicates unless genuine questions exist.	Yes—state must produce the original if authenticity is genuinely questioned.	No—duplicate is acceptable without concrete evidence of inauthenticity or unfairness.
Whether a denial alone from a party is enough to trigger the original-only requirement under OEC 1003.	No—must be more than speculation; denial alone insufficient.	Yes—denying signature raises enough of an authenticity issue.	No—a genuine issue requires more than denial; must be specific evidence suggesting forgery or alteration.
Appropriateness of jury deciding on authenticity versus exclusion by the judge.	Jury should weigh evidence and decide credibility.	Court should exclude questionable duplicate before jury review.	Jury decides; judge should not preclude evidence on mere denial alone.

State v. White, 4 Or App 151 (explains purpose of the best evidence rule to ensure reliability of dispute document contents)
State v. Engle, 278 Or App 54 (standard for appellate review of evidentiary rulings)
Sisters of St. Joseph v. Wyllie, 120 Or App 474 (addressing summary judgment and authenticity of consent forms)
State v. Cornell, 109 Or App 396 (permitting Oregon courts to use federal case law for interpreting paralleling evidence rules)