Commonwealth v. Quentin Smith

Summary

The court held that testimony about a database search for the absence of a public record is admissible when the witness is familiar with the search process and the relevant government record-keeping practices. The testimony did not violate confrontation rights because the firearm-license records were created for administrative purposes rather than to establish facts for trial. The convictions were nevertheless reversed because the Commonwealth did not present substantive evidence that the birth date used in the search belonged to the defendant.