Supreme Court of Virginia

Sanders v. Com.

June 9, 2011282 Va. 154

Summary

The Supreme Court of Virginia affirmed Sanders' convictions, holding that the laboratory report on which the expert relied was created for medical treatment purposes and therefore was non‑testimonial for Sixth Amendment confrontation purposes.

Holding

  • Whether the laboratory report relied upon by the expert was testimonial for purposes of the Sixth Amendment Confrontation Clause.. The laboratory report was not testimonial because it was created for medical treatment purposes; consequently, the Confrontation Clause was not violated and the conviction stands.

Docket 101870

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