State of New Jersey, Plaintiff-Respondent v. Julie L. Michaels A/K/A Lynn Michaels, Julie Lynn, Joline Brooks…

Summary

The New Jersey Supreme Court held that the admission of a forensic laboratory report and the testimony of the supervising toxicologist did not violate the Sixth Amendment Confrontation Clause, affirming the defendant's conviction. The Court reasoned that the supervisor, who reviewed the machine‑generated data and certified the report, was a knowledgeable witness whose cross‑examination satisfied the defendant's confrontation rights. Justice Albin dissented, arguing that the surrogate testimony infringed the Confrontation Clause.