State v. Brewington
Annotate this CaseAfter a trial, Defendant was convicted of possession of cocaine. The court of appeals reversed and ordered a new trial, concluding that Defendant's Confrontation Clause rights were violated when the trial court permitted a State Bureau of Investigation (SBI) special agent to testify that the substance found on Defendant was cocaine based solely on her supervisor's notes and lab report. The Supreme Court reversed, holding that Defendant's Confrontation Clause rights were not violated where (1) the SBI agent presented an independent opinion formed as a result of her own analysis, not surrogate testimony; (2) Defendant was able to conduct a cross-examination that exposed the weaknesses in the agent's testimony; and (3) the supervisor's lab notes were not admitted into evidence.
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