(Download) "State v. Caulfield" by Supreme Court of Montana * eBook PDF Kindle ePub Free
eBook details
- Title: State v. Caulfield
- Author : Supreme Court of Montana
- Release Date : January 05, 2006
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 66 KB
Description
Appellant Scott Caulfield challenges his conviction of possession of a controlled substance with intent to sell. Caulfield argues that a Bureau of Criminal Apprehension (BCA) laboratory report identifying a substance seized from him as cocaine was testimonial evidence under Crawford v. Washington, 541 U.S. 36 (2004). He contends that his confrontation rights were violated because the report was admitted into evidence even though the BCA analyst who prepared the report did not testify at trial. He also argues that Minn. Stat. § 634.15 (2004) violated his confrontation rights under the United States Constitution because it required him to request the testimony of the analyst 10 days before trial. We hold that the report is testimonial and that its admission, under the statute permitting its introduction without the testimony of the analyst, violated Caulfields rights under the Confrontation Clause. We also determine that the error in admitting the report was not harmless beyond a reasonable doubt and therefore reverse and remand for a new trial. During the fall of 2001, employees at Kathys Pub in Rochester, Minnesota noticed the unusual behavior of Scott Caulfield, a frequent customer. Caulfield would repeatedly go into a back hallway or alley with people who had approached him in the bar, then return after 10 to 15 minutes.