laboratory test (Mississippi) · Go Syfert
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laboratory test in Mississippi

13 Mississippi opinions name it 2 courts 1971–2015 0 in the last five years

The cases below were cited by Mississippi courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Kettle v. Stategreen
miss · 1994 · cited in 7 Mississippi opinions naming this issue, 1995–2012
2 sentences

2012Despite the majority’s protests to the contrary, Justice Kennedy was correct in suggesting that McGowen was not entirely consistent with this Court’s holding in Barnette v. State, 481 So.2d 788, 791 (Miss.1985), “that it was reversible error to admit, over the objection of [the defendant], the certificate of analysis into evidence without the testimony of the analyst who prepared such.” (Emphasis added.) See also Kettle v. State, 641 So.2d 746, 750 (Miss.1994) (“We hold that ... when someone other than the person who conducted the laboratory test attempts to testify in a cocaine possession or

2012Despite the majority’s protests to the contrary, Justice Kennedy was correct in suggesting that McGowen was not entirely consistent with this Court’s holding in Barnette v. State, 481 So.2d 788, 791 (Miss.1985), “that it was reversible error to admit, over the objection of [the defendant], the certificate of analysis into evidence without the testimony of the analyst who prepared such.” (Emphasis added.) See also Kettle v. State, 641 So.2d 746, 750 (Miss.1994) (“We hold that ... when someone other than the person who conducted the laboratory test attempts to testify in a cocaine possession or

47
Barnette v. Stategreen
miss · 1985 · cited in 2 Mississippi opinions naming this issue, 2012–2012
2 sentences

2012Despite the majority’s protests to the contrary, Justice Kennedy was correct in suggesting that McGowen was not entirely consistent with this Court’s holding in Barnette v. State, 481 So.2d 788, 791 (Miss.1985), “that it was reversible error to admit, over the objection of [the defendant], the certificate of analysis into evidence without the testimony of the analyst who prepared such.” (Emphasis added.) See also Kettle v. State, 641 So.2d 746, 750 (Miss.1994) (“We hold that ... when someone other than the person who conducted the laboratory test attempts to testify in a cocaine possession or

2012Despite the majority’s protests to the contrary, Justice Kennedy was correct in suggesting that McGowen was not entirely consistent with this Court’s holding in Barnette v. State, 481 So.2d 788, 791 (Miss.1985), “that it was reversible error to admit, over the objection of [the defendant], the certificate of analysis into evidence without the testimony of the analyst who prepared such.” (Emphasis added.) See also Kettle v. State, 641 So.2d 746, 750 (Miss.1994) (“We hold that ... when someone other than the person who conducted the laboratory test attempts to testify in a cocaine possession or

22
Adams v. Stategreen
missctapp · 2001 · cited in 2 Mississippi opinions naming this issue, 2012–2012
2 sentences

2012In distinguishing Barnette and Kettle, McGowen relied on Adams v. State, 794 So.2d 1049, 1057-58 (Miss.Ct.App.2001); but, even in Adams, 794 So.2d at 1057 , the testifying witness was a laboratory supervisor who had “supervised, witnessed, and checked the tests performed by his technician.” ¶ 31.

2012In distinguishing Barnette and Kettle, McGowen relied on Adams v. State, 794 So.2d 1049, 1057-58 (Miss.Ct.App.2001); but, even in Adams, 794 So.2d at 1057 , the testifying witness was a laboratory supervisor who had “supervised, witnessed, and checked the tests performed by his technician.” ¶ 31.

22
Wells v. Stategreen
miss · 1992 · cited in 1 Mississippi opinions naming this issue, 1995–1995
1 sentence

1995Mississippi Rule of Evidence 901(a) states: "The requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims." The Mississippi Supreme Court has held that the test for chain of custody is "whether there is any indication of tampering or substitution of evidence." Wells v. State, 604 So. 2d 271, 277 (Miss. 1992).

11
Ohio v. Robertsred
scotus · 1980 · cited in 1 Mississippi opinions naming this issue, 1994–1994
2 sentences

1994In Estelle and King no Sixth Amendment question was raised, but in Ormond we recognized that the Sixth Amendment right to confrontation could arise in such a case, Id. at 959 , but nevertheless held that there was no error in admitting the doctor's testimony. [1] When the Sixth Amendment right to confrontation arises, the ultimate question is whether hearsay evidence offered qualifies under a "firmly rooted hearsay exception." Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531, 2539 , 65 L.Ed.2d 597, 608 (1980).

1994In Estelle and King no Sixth Amendment question was raised, but in Ormond we recognized that the Sixth Amendment right to confrontation could arise in such a case, Id. at 959 , but nevertheless held that there was no error in admitting the doctor's testimony. [1] When the Sixth Amendment right to confrontation arises, the ultimate question is whether hearsay evidence offered qualifies under a "firmly rooted hearsay exception." Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531, 2539 , 65 L.Ed.2d 597, 608 (1980).

11
Ormond v. Stategreen
miss · 1992 · cited in 1 Mississippi opinions naming this issue, 1994–1994
2 sentences

1994And, in Ormond v. State, 599 So.2d 951, 958-59 (Miss. 1992), we approved a doctor testifying that the accused had gonorrhea based upon a laboratory test made by a nurse.

1994In Estelle and King no Sixth Amendment question was raised, but in Ormond we recognized that the Sixth Amendment right to confrontation could arise in such a case, Id. at 959 , but nevertheless held that there was no error in admitting the doctor's testimony. [1] When the Sixth Amendment right to confrontation arises, the ultimate question is whether hearsay evidence offered qualifies under a "firmly rooted hearsay exception." Ohio v. Roberts, 448 U.S. 56, 66 , 100 S.Ct. 2531, 2539 , 65 L.Ed.2d 597, 608 (1980).

11
State v. Bellardgreen
la · 1988 · cited in 1 Mississippi opinions naming this issue, 1988–1988
1 sentence

1988See also State v. Bellard, 533 So.2d 961 (La. 1988) (Same); State v. Walker, 489 So.2d 353 (La.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Mississippi. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Deloach v. State green
miss · 1995
1 sentence

2015Id. at 876 .

12015–2015
California v. Trombetta green
scotus · 1984
2 sentences

2000Id. at 490 , 104 S.Ct. 2528 . ¶ 9.

2000Id. at 490 , 104 S.Ct. 2528 . ¶ 9.

12000–2000
State v. Walker neutral
lactapp · 1986
1 sentence

1988See also State v. Bellard, 533 So.2d 961 (La. 1988) (Same); State v. Walker, 489 So.2d 353 (La.

11988–1988
Lee v. State green
alaska · 1973
1 sentence

1974In rejecting defendant's argument, the Court said: In those cases where expert analysis exhausts the substance there is clearly no error in the admission of evidence regarding the analysis in the absence of allegations and proof of deliberate destruction, or deliberate attempts to avoid discovery of evidence beneficial to the defense. 511 P.2d at 1077 .

11974–1974
Spears v. State green
miss · 1970
1 sentence

1971In the recent case of Spears v. State, 241 So.2d 148 (Miss. 1970), we held that to allow a doctor to express an opinion as to pregnancy based upon a laboratory test not performed by the doctor was denial of the basic and fundamental right to be confronted by the witness as well as the right of cross examination.

11971–1971

Where else courts name it

NY 56 (1964–2024) CA 47 (1953–2025) TX 38 (1963–2025) IL 22 (1968–2025) OH 17 (1991–2026) VA 14 (1971–2024) MS 13 (1971–2015) NJ 12 (1986–2025) NM 9 (2001–2018) IN 7 (1931–2016) GA 7 (1977–2003) MD 7 (2000–2018) MO 6 (1940–2021) MA 6 (1940–2018) CT 6 (1938–2026) FL 6 (1994–2015) DC 6 (1991–2017) WA 5 (1984–2026) NC 5 (1961–2005) PA 5 (1971–2020) KS 4 (1927–2009) TN 4 (1995–2017) WI 4 (2014–2025) AK 4 (1971–2010) MN 4 (1965–2009) AZ 3 (1983–2022) NH 3 (1974–2007) AR 3 (1994–2020) LA 3 (1997–2012) MI 3 (1971–2015) ID 2 (2016–2016) MT 2 (1978–1991) VT 2 (1996–2003) NV 2 (1992–2020) SC 2 (2001–2001) IA 2 (2008–2008) OR 2 (1982–1991)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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