People v. Lopez
California Supreme Court
286 P.3d 469 (2012)
Virginia Lopez (defendant) was charged with vehicular manslaughter while intoxicated. To prove that Lopez was intoxicated at the time of the offense, the State of California (plaintiff) relied on a blood-alcohol report prepared by laboratory analyst Jorge Peña. Peña did not testify at trial. Five pages of Peña’s report contained only data generated by a gas-chromatography machine regarding the machine’s calibration, quality control, and measurement of the alcohol concentration of Lopez’s blood sample. Peña signed one of the five pages of data and initialed the others, but there were no express or implied statements from Peña on those pages. Lopez was convicted. On appeal to the California Supreme Court, Lopez argued that Peña’s report was testimonial hearsay and that admitting the report violated the Confrontation Clause of the Sixth Amendment.
Rule of Law
Holding and Reasoning (Kennard, J.)
Dissent (Liu, J.)
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