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Home / Courts / Criminal Practice – Constitutional – Confrontation Clause – Drug Analysis – Lay Witness – Plain Error (access required)

Criminal Practice – Constitutional – Confrontation Clause – Drug Analysis – Lay Witness – Plain Error (access required)

State v. Burrow The pills seized from defendant were identified only in an SBI report. The SBI analyst did not testify, and there was no indication that he was unavailable. It was plain error for the trial court to admit the SBI report through the testimony of a lay witness, a police detective.

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