Strobel v. State, 322 Ga. App. 569

Defendant Steven Strobel convicted by jury of first-degree arson after an early-morning house fire at his girlfriend’s home; appeal challenges admission of hotel credit-card receipts.
Fire investigators and a State Farm investigator concluded the fire was intentionally set and detected gasoline and incendiary burn patterns.
Evidence showed the couple was absent from the home, personal items missing from the house, and many of the girlfriend’s belongings later found at Strobel’s home and storage units.
Strobel earlier told investigators he and his girlfriend traveled to Washington, D.C.; he later admitted lying about that trip and initially told an arson investigator he drove her to set the house on fire, but at trial he denied involvement.
Deputies recovered two hotel credit-card receipts from a Charlotte hotel dated January 18–19; Strobel objected at trial that the receipts were unauthenticated business records.
Trial court admitted the receipts; on appeal the court assumed without deciding foundation was insufficient but held any error harmless because receipts were cumulative of Strobel’s admissions about being in Charlotte.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of hotel credit-card receipts under business-records hearsay exception	State: receipts admissible or any foundation objection is collateral; receipts corroborate travel	Strobel: receipts were unauthenticated business records and lacked proper foundation under OCGA § 24-3-14	Even if foundation lacking, admission was harmless error because receipts were cumulative of Strobel’s own testimony admitting he lied about the Washington trip and had gone to Charlotte

Jackson v. State, 252 Ga. App. 268 (discusses standard of review on appeal from criminal conviction)
Ross v. State, 298 Ga. App. 525 (explains foundation needed for business-records hearsay exception)
Taylor v. State, 249 Ga. App. 538 (harmless-error analysis for cumulative evidence)