This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- In October 2004, a ten-month-old child was taken to the emergency room by his mother and the Defendant, showing symptoms including internal cranial bleeding. The child was later pronounced dead in Lubbock, Texas. An autopsy performed determined the cause of death as closed head injuries, ruling it a homicide. The State sought to use the autopsy report at trial, but the original examiner required a prohibitive fee for testimony, leading the State to use the examiner's former supervisor as a witness instead (paras 2-3).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant: Argued that admitting the autopsy report and allowing testimony about its contents violated the Confrontation Clause of the Sixth Amendment, as the report was testimonial in nature and the author was not made available for cross-examination (para 4).
- State: Contended that the autopsy report should be admissible as evidence because it was the type of information upon which experts in the field would rely, and if the testifying expert believed the information to be accurate, it should be entered into evidence (para 7).
Legal Issues
- Whether the admission of the autopsy report and the testimony of its contents by a different medical examiner violated the Defendant's confrontation rights under the Sixth Amendment (paras 6, 9-11).
Disposition
- The court reversed the Defendant's conviction due to constitutional error in admitting the autopsy report, which violated the Defendant's confrontation rights (para 1).
Reasons
-
The court, with Judge Roderick T. Kennedy authoring the opinion and Judges Celia Foy Castillo and Cynthia A. Fry concurring, found that the autopsy report was testimonial in nature. Since the Defendant had no opportunity to cross-examine the report's author, and the author was not shown to be unavailable, admitting the report violated the Confrontation Clause. The court determined that the report's admission was not harmless error, as it was critical to the State's case, and thus reversed the conviction and remanded for a new trial (paras 9-25).
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