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Simms v. Dixon

District of Columbia Court of Appeals
291 A.2d 184 (D.C. App. 1972)


Cheryl Simms and Herbert Dixon were involved in an auto accident. Dixon testified that the collision occurred when Simms suddenly turned her car into the path of his car and his car struck Simms’ car across the middle. Simms testified that she signaled for a right turn and when making that turn, Dixon’s car struck her car on the rear right side. At trial, Simms sought to introduce six photographs of her car after the collision. The purpose of the photographs was to show the site of the impact on Simms’ car. Simms’ counsel maintained that he could lay the foundation for the photos’ admission through Simms. The trial court refused to admit the photos unless the photographer testified and laid the foundation. Simms lost at trial, and appealed.

Rule of Law


Holding and Reasoning (Fickling, J.)

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