Section 98 Admissibility of Lab Reports
| Library | DWI Experts and the Science of Chemical Tests 2014 |
Under State v. March, 216 S.W.3d 663 (Mo. banc 2007), in Missouri, laboratory reports are no longer admissible without the supporting witness (admitting lab report of a chemist violates the Confrontation Clause of the Sixth Amendment as in Crawford v. Washington, 541 U.S. 36 (2004)). The Supreme Court has continued to support the examination of the person doing the testing after Crawford, 541 U.S. at 36. Melendez-Diaz v. Mass., 557 U.S. 305, 330 (2009); Bullcoming v. N.M., 131 S. Ct. 2705 (2011). This is...
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