Bullcoming v. New Mexico
United States Supreme Court
564 U.S. 647 (2011)
After Donald Bullcoming (defendant) was suspected of drunk driving, forensic analyst Curtis Caylor tested his blood sample and signed a certification reporting a high blood-alcohol content and averring the test was properly administered; at trial, New Mexico (plaintiff) introduced Caylor's report but called a different scientist, Gerasimos Razatos, who had not participated in or observed the actual testing, to testify about it instead. Bullcoming objected on Confrontation Clause grounds, but the trial court admitted the report as a business record, and he was convicted; the New Mexico Supreme Court upheld the conviction, reasoning Caylor had merely transcribed machine-generated results and that Razatos's expert testimony adequately preserved Bullcoming's confrontation rights, and the U.S. Supreme Court granted certiorari.
Whether the Confrontation Clause permits the prosecution to introduce a testimonial forensic laboratory report through the in-court testimony of an analyst who did not sign the certification or personally perform or observe the test.