California Supreme Court
The People, Plaintiff and Respondent v. Virginia Hernandez Lopez, Defendant and Appellant
October 15, 201255 Cal. 4th 569
Summary
The court held that the laboratory report and related testimony did not violate the defendant's confrontation right because the challenged sample-identification notation lacked the formality or solemnity required for testimonial hearsay, and the machine-generated data contained no human statement. The court further concluded that any potentially testimonial notations were harmless beyond a reasonable doubt because the testifying criminalist independently reached the same blood-alcohol result. Justice Werdegar concurred in the result on a similar ground, Justice Corrigan concurred based primarily on the business-record purpose of the notations, and Justice Liu dissented, reasoning that the crime-laboratory records were testimonial and their admission was prejudicial.