People v. Veamatahau
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The Supreme Court affirmed the judgment of the court of appeals concluding that the admission of expert testimony did not violate the prohibition against communication of case-specific hearsay set forth in People v. Sanchez, 63 Cal.4th 665 (2016) and that sufficient evidence supported Defendant's conviction for possession of alprazolam, holding that the court of appeal did not err.
Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for his or her opinion unless the facts are independently proven or fall within a hearsay exception. In the instant case, an expert told the jury that he identified the controlled substance Defendant was charged with possessing by comparing the visual characteristics of the pills seized against a database containing descriptions of pharmaceuticals. On appeal, Defendant argued that the expert related inadmissible case-specific hearsay. The court of appeal affirmed. The Supreme Court affirmed, holding (1) the expert related no inadmissible case-specific hearsay in testifying to the contents of a drug identification database; and (2) substantial evidence supported Defendant's conviction.
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