South Carolina v. Brewer
Annotate this CaseAngela Brewer was convicted of homicide by child abuse after her thirteen-month-old grandson died from drinking lemonade mixed with oxycodone. Brewer contended the court of appeals erred in upholding the trial court's admission of an interrogation video when she was under the influence of medication. She also raised an issue relating to the scope of the Sixth Amendment's Confrontation Clause when the State sought to introduce the contents of a toxicology report from an out-of-state laboratory through a pathologist who did not perform the actual testing. The trial court concluded the toxicology report was not testimonial in nature, thereby removing it from the confines of the Sixth Amendment, and the court of appeals affirmed. While the South Carolina Supreme Court saw no error in admitting the interrogation video, it reversed Brewer's conviction and sentence based on a Confrontation Clause violation: "the Confrontation Clause mandates that an individual who actually performed the forensic testing be subject to cross- examination."
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