completion analysis in Alabama

2002In order to establish a proper chain, the State must show to a `reasonable probability that the object is in the same condition as, and not substantially different from, its condition at the commencement of the chain.'" Ex parte Holton, 590 So.2d 918, 919-20 (Ala.1991) (citations omitted). "`[W]hen dealing with a controlled substance, "the law is concerned with tracing the integrity of the substance only up through the completion of the analysis." Congo v. State, 409 So.2d 475, 479 (Ala.Crim.App.1981), cert. denied, 412 So.2d 276 (Ala.1982).

1995Although there was no testimony concerning the disposition of Exhibits 68 and 70 after Ms. Rollan and Ms. Scott completed their testing, "[h]ere, as when dealing with a controlled substance, 'the law is concerned with tracing the integrity of the substance only up through the completion of the analysis.' Congo v. State , 409 So.2d 475 , 479 (Ala.Cr.App. 1981), cert. denied, 412 So.2d 276 (Ala. 1982). 'Any alteration or substitution of the items after [the expert] finished her analysis and comparison would, therefore, have been immaterial.' Blanco v. State , 485 So.2d 1217 , 1219 (Ala.Cr.App. 1

1999This claim is without merit. "`[T]he law is concerned with tracing the integrity of the substance only up through the completion of the analysis.'" Land v. State , 678 So.2d 201 , 213 (Ala.Cr.App. 1995), aff'd, 678 So.2d 224 (Ala.), cert. denied, 519 U.S. 933 , 117 S.Ct. 308 , 136 L.Ed.2d 224 (1996) (citations omitted).

1999This claim is without merit. "`[T]he law is concerned with tracing the integrity of the substance only up through the completion of the analysis.'" Land v. State , 678 So.2d 201 , 213 (Ala.Cr.App. 1995), aff'd, 678 So.2d 224 (Ala.), cert. denied, 519 U.S. 933 , 117 S.Ct. 308 , 136 L.Ed.2d 224 (1996) (citations omitted).

1999This claim is without merit. "`[T]he law is concerned with tracing the integrity of the substance only up through the completion of the analysis.'" Land v. State , 678 So.2d 201 , 213 (Ala.Cr.App. 1995), aff'd, 678 So.2d 224 (Ala.), cert. denied, 519 U.S. 933 , 117 S.Ct. 308 , 136 L.Ed.2d 224 (1996) (citations omitted).

1999This claim is without merit. "`[T]he law is concerned with tracing the integrity of the substance only up through the completion of the analysis.'" Land v. State , 678 So.2d 201 , 213 (Ala.Cr.App. 1995), aff'd, 678 So.2d 224 (Ala.), cert. denied, 519 U.S. 933 , 117 S.Ct. 308 , 136 L.Ed.2d 224 (1996) (citations omitted).

1999This claim is without merit. "`[T]he law is concerned with tracing the integrity of the substance only up through the completion of the analysis.'" Land v. State , 678 So.2d 201 , 213 (Ala.Cr.App. 1995), aff'd, 678 So.2d 224 (Ala.), cert. denied, 519 U.S. 933 , 117 S.Ct. 308 , 136 L.Ed.2d 224 (1996) (citations omitted).

1995As we have previously observed, under these circumstances, "the law is concerned with tracing the integrity of the substance only up through the completion of the analysis." Congo v. State , 409 So.2d at 479 , quoted in Parker v. State , 587 So.2d at 1089 , and Smith v. State , 588 So.2d at 581 .

1995Although there was no testimony concerning the disposition of Exhibits 68 and 70 after Ms. Rollan and Ms. Scott completed their testing, "[h]ere, as when dealing with a controlled substance, 'the law is concerned with tracing the integrity of the substance only up through the completion of the analysis.' Congo v. State , 409 So.2d 475 , 479 (Ala.Cr.App. 1981), cert. denied, 412 So.2d 276 (Ala. 1982). 'Any alteration or substitution of the items after [the expert] finished her analysis and comparison would, therefore, have been immaterial.' Blanco v. State , 485 So.2d 1217 , 1219 (Ala.Cr.App. 1

1981In the present case, any tampering with the evidence by the Huntsville property custodian, which we deem a "remote possibility," see Mauldin v. State , Ala.Cr.App., 402 So.2d 1106 (1981), would not have affected Ms. Odom's conclusion that the pills contained a controlled substance and would not have invalidated the chain of custody.

1947Petitioner thereupon perfected his appeal to this court. • In an excellent, and we think well nigh definitive opinion by Bricken, Presiding Judge, in Robertson v. State, 20 Ala.App. 514 , 104 So. 561, 567 , dealing with the question of contempt proceedings for failing to pay alimony, this court determined that such proceedings are sui generis, collateral to but independent of the cause in which the contempt arises, and while technically classified as a civil contempt, it is also quasi criminal, the elements" of both a criminal and a "civil proceeding appearing.

1947Petitioner thereupon perfected his appeal to this court. • In an excellent, and we think well nigh definitive opinion by Bricken, Presiding Judge, in Robertson v. State, 20 Ala.App. 514 , 104 So. 561, 567 , dealing with the question of contempt proceedings for failing to pay alimony, this court determined that such proceedings are sui generis, collateral to but independent of the cause in which the contempt arises, and while technically classified as a civil contempt, it is also quasi criminal, the elements" of both a criminal and a "civil proceeding appearing.

1867Lowther v. Chappell, 8 Ala. 353 , and authorities cited; Angell on limitations, § 260, and note 4.