The People, Plaintiff and Respondent v. Virginia Hernandez Lopez, Defendant and Appellant — Corrigan, J., Concurring

Summary

Justice Corrigan concurred in the majority’s result but would have analyzed the confrontation issue under the primary-purpose inquiry rather than chiefly by the report’s formality. She concluded that routine identification and tracking entries were nontestimonial business records, while assuming that other entries were testimonial but harmless because independent machine-generated results and expert testimony supplied the same evidence. Justice Liu, dissenting, would have found the laboratory records testimonial and the admission prejudicial because the surrogate witness lacked personal knowledge.