State v. Julie L. Michaels (072106)
95 A.3d 648
| N.J. | 2014Background
- Michaels was charged with vehicular homicide, assault by auto, and related offenses after a head-on collision.
- Blood tests at hospital showed cocaine, alprazolam, and benzoethylene; marijuana negative.
- Private lab (NMS) performed 950 pages of testing; four dozen technicians involved.
- Dr. Barbieri, a supervisor at NMS, reviewed data and certified a signed laboratory report.
- Barbieri testified and the report was admitted without calling all analysts; defendant objected under the Confrontation Clause.
- Appellate Division and trial court upheld the conviction; Supreme Court granted review to address confrontation concerns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admitting the lab report violated Confrontation Clause rights | Michaels; Barbierri’s testimony suffices as independent review | Bullcoming standard requires confronting the performing analysts | No violation; supervisor testimony satisfies confrontation rights |
| Whether Dr. Barbieri’s testimony was properly admissible under Rule 703 | Barbieri relied on machine data and calibration/quality controls | Should have called primary analysts or treated data as testimonial | Admissible; Barbieri’s independent review and certification justified testimony under 703 |
| Whether Williams/Bullcoming/Melendez-Diaz compel calling all analysts in such private-lab testing | Bullcoming requires confrontation of the analyst who performed the test | Williams creates ambiguity; strict sourcing unnecessary | No; majority allows a knowledgeable supervisor to testify based on independent review; not required to call every analyst |
Key Cases Cited
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (forensic certificates are testimonial; must confront analysts)
- Bullcoming v. New Mexico, 564 U.S. 647 (U.S. 2011) (surrogate testimony cannot substitute for confronting the testifying analyst)
- Williams v. Illinois, 567 U.S. 50 (U.S. 2012) (forensic DNA/identity discussions; fractured plurality; not decisive law for all labs)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements require confrontation absent unavailability and prior cross-examination)