Supervising chemist can
testify in vehicular homicide if they independently verified correctness of blood
test results State v. Michaels __ NJ__ (2014) (A-69-12)
Defendant’s confrontation rights were not
violated by the admission of Dr. Barbieri’s report or his testimony regarding
the blood tests and his conclusions drawn therefrom. Dr. Barbieri was
knowledgeable about the testing process, independently verified the correctness
of the machine-tested processes and results, and formed an independent
conclusion about the results. Defendant’s opportunity to cross-examine Dr.
Barbieri satisfied her right to confrontation on the forensic evidence
presented against her.
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