People v. Stamps, A142424M

Latanya Stamps was stopped and searched four times in Oct–Dec 2012; police found pills and crystalline substances in her car, purse, or clothing.
Criminalist Shana Meldrum chemically tested the crystalline substances (confirmed methamphetamine/cocaine) but did not chemically test the pills.
Meldrum identified the pills as oxycodone and dihydrocodeinone solely by visually matching pill markings, shape, and color to photographs on the Ident‑A‑Drug website.
Stamps admitted to police that some pills were Norco and Phexoreal, but no chemical analysis tied those labels to the controlled substances charged.
Jury convicted Stamps on eight counts (three meth, one cocaine, one oxycodone, three dihydrocodeinone); appeal challenges admission of the Ident‑A‑Drug‑based testimony and sufficiency of evidence for pill counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of expert testimony repeating Ident‑A‑Drug website	The expert testimony was permissible background/expert basis and any objection was forfeited	Meldrum’s testimony relayed inadmissible case‑specific hearsay and used no expertise beyond reading a website	Reversed pill convictions: Ident‑A‑Drug testimony was case‑specific hearsay (Sanchez) and inadmissible absent an exception
Whether matching pills to website required expert skill	The comparison was within expert testimony latitude; it aided the jury	The matching involved no specialized expertise and the witness was a mere conduit for hearsay	Court: Meldrum added no expertise; she merely repeated website content and amplified hearsay
Harmless‑error as to pill convictions	Admission was harmless because of other evidence (e.g., admissions)	Admission was prejudicial because Ident‑A‑Drug was the only evidence proving chemical composition	Error was not harmless under People v. Watson; reversal of pill counts required
Double jeopardy / sufficiency for retrial	Convictions were supported such that retrial is barred	Admission was erroneous but the record still contained evidence that could support conviction	Retrial not barred: evidence as presented was not so insufficient as to preclude retrial (Burks/Lockhart principles)

People v. Sanchez, 63 Cal.4th 665 (Cal. 2016) (case‑specific out‑of‑court statements treated as true by an expert are hearsay and inadmissible absent exception)
People v. Gardeley, 14 Cal.4th 605 (Cal. 1996) (prior rule allowing experts to relate inadmissible matter as basis for opinion, subject to reliability limits)
Sargon Enterprises, Inc. v. University of Southern California, 55 Cal.4th 747 (Cal. 2012) (trial court gatekeeping duty to exclude expert opinion based on unreliable or improper material)
People v. Watson, 46 Cal.2d 818 (Cal. 1956) (state standard for harmless error review)
Burks v. United States, 437 U.S. 1 (U.S. 1978) (double jeopardy bars retrial when conviction is reversed for insufficiency of evidence)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of the evidence)
Lockhart v. Nelson, 488 U.S. 33 (U.S. 1988) (distinction between evidentiary error and insufficiency that bars retrial)
People v. Montiel, 5 Cal.4th 877 (Cal. 1993) (discussing limits on admitting out‑of‑court statements as bases for expert opinion)