Court of Criminal Appeals of Texas
Robert Nicholas Angleton, Appellant v. the State of Texas
May 27, 19981998 Tex. Crim. App. LEXIS 70
Summary
The Court overruled Kephart, holding that Rule 901 does not require a witness with personal knowledge to authenticate a tape recording. It found the trial court did not abuse its discretion in admitting the audio tape and therefore reversed the Court of Appeals judgment, remanding for further proof‑evident analysis.