4. (§19.29) Maps
Maps typically present a hybrid evidentiary analysis, different from most diagrams and drawings, in that most maps tend to be commercially prepared, whereas most diagrams and drawings that are the subject of appellate review are specifically prepared by the parties for the litigation at hand. Thus, the inherent question about the reliability and trustworthiness associated with lawsuit-specific diagrams and drawings is often not present with commercially prepared maps.
Missouri law is sufficiently clear that courts may take judicial notice of geographical facts, including official maps. State v. Hammons, 964 S.W.2d 509 (Mo. App. W.D. 1998); Meyer v. Dir. of Revenue, 909 S.W.2d 397 (Mo. App. W.D. 1995). This includes the location of cities and towns, the location of county lines, and the routes of highways. Siehndel v. Russell-Fischer, 114 S.W.3d 449 (Mo. App. W.D. 2003) (using an official map, the court took judicial notice that Interstate 29 passes through the city of Northmoor). The caselaw does not indicate exactly what an “official” map is, though; presumably, it refers to a map commercially prepared by a disinterested third party in the business of cartography.
How the map is used at trial is largely up to the proponent of the evidence. Because courts do take judicial notice of official maps, unlike most drawings and diagrams prepared by counsel or the parties, the use of maps is not limited to assisting in the understanding of verbal testimony of witnesses. Maps may be offered into evidence ipso facto to prove the truth of that which...
