People v. Rutterschmidt
Annotate this CaseDefendant and Codefendant were charged with murdering two men by running over each of them with a car. The prosecution's theory was that one of the two victims had been drugged before he was killed. To prove this point, the prosecution presented the testimony of a laboratory director who, relying on reports not prepared by him, testified that testing of the victim's blood samples by analysts at his laboratory had determined the presence of drugs that could have caused drowsiness. According to Defendant, that testimony violated her Sixth Amendment right to confront and cross-examine the analysts who had tested the blood samples. The jury found both Defendant and Codefendant guilty of two counts of first degree murder and two counts of conspiracy to commit murder. The court of appeal affirmed, holding that even if there was a confrontation right violation, the error was not prejudicial. The Supreme Court affirmed, holding that in light of the overwhelming evidence against Defendant, exclusion of the laboratory director's trial testimony would, beyond a reasonable doubt, not have affected the outcome of Defendant's trial.
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