State v. Snead, 368 N.C. 811

Defendant Snead admitted he was one of two men captured on Belk’s surveillance video stealing shirts; dispute centered solely on quantity and value (felony threshold > $1,000).
Belk’s regional loss-prevention manager, Toby Steckler, testified about the store’s digital surveillance system, its anti-tampering safeguards, and that the CD played at trial matched the recorder’s footage.
Steckler estimated, from the video and store-stocking practices, that Snead stole 20–30 Ralph Lauren Polo shirts (valued $85–$89.50 each) and that an accomplice stole several $95 sweatshirts.
Defense objected outside the jury to authentication of the video (arguing Steckler was not present during the theft) and to Steckler’s valuation testimony (arguing lack of personal knowledge), but did not object when Steckler gave those estimates in front of the jury.
The trial court admitted the video and Steckler’s testimony; the jury convicted Snead of felony larceny and conspiracy. The Court of Appeals vacated the felony larceny conviction, finding authentication error and that Steckler’s lay-value opinion lacked basis.
The State petitioned for discretionary review to the North Carolina Supreme Court.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Snead)	Held
Whether surveillance video was properly authenticated under Rule 901	Steckler’s testimony about system reliability, safeguards, and that the CD matched the recorder sufficiently authenticated the video	Steckler was not present at the time of the theft and thus could not testify the video fairly and accurately depicted the event	Video was properly authenticated under Rule 901; admission was not error
Whether Steckler’s estimate of quantity/value was admissible lay opinion	Steckler’s familiarity with merchandise, display practices, and the video supported a permissible lay opinion about quantity and value	Testimony lacked firsthand perception or personal knowledge to support valuation and quantity estimates	Issue not preserved: defendant failed to object when testimony was elicited before the jury; appellate review waived

State v. Campbell, 311 N.C. 386 (discussing admissibility of real evidence and need for showing no material change)
State v. Kistle, 59 N.C. App. 724 (addressing when full chain of custody is unnecessary for identifiable items)
State v. Ray, 364 N.C. 272 (timeliness requirement for objections to preserve issues on appeal)
State v. Thibodeaux, 352 N.C. 570 (same rule on timing of objections)
State v. Brent, 367 N.C. 73 (same rule on objection timing)
State v. Gladden, 315 N.C. 398 (failure to object at time evidence offered precludes relief)
United States v. Pinke, [citation="614 F. App'x 651"] (witness testimony about video system operation and downloading sufficient to authenticate footage)