United States v. Jade Jackson
690 F. App'x 830
4th Cir.2017Background
- In 2012, Jade Clayton Jackson pleaded guilty to involuntary manslaughter and driving with a revoked license; he was sentenced to 51 months imprisonment plus 3 years of supervised release.
- After release, Jackson’s supervised release was revoked and he received a 24-month prison sentence.
- At the revocation hearing, a laboratory technician testified she reviewed machine-generated raw data (from tests performed by other technicians) and concluded Jackson’s urine samples were positive for PCP.
- The government also offered laboratory reports signed by certifying technicians who did not testify; those reports likewise indicated PCP presence.
- Jackson argued admission of the technician’s testimony and the out-of-court certifying reports violated his right to confront adverse witnesses and were inadmissible hearsay under Rule 32.1.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of testimony by supervising technician who reviewed machine-generated data | Jackson: testimony impermissible because tests were conducted by other technicians and he couldn’t confront them | Gov: supervising chemist may testify based on review of machine data even if other techs ran the tests | Court: Admissible — supervising technician may testify to machine-generated data (no confrontation violation) |
| Admissibility of lab reports by non-testifying certifying technicians | Jackson: reports are hearsay and admission denied his confrontation rights | Gov: reports corroborate test results and technician testimony; producing witnesses not required for good cause | Court: Any error in admitting those reports was harmless given admissible testimony to same effect |
Key Cases Cited
- United States v. Ferguson, 752 F.3d 613 (4th Cir. 2014) (standard for harmless error review and Rule 32.1 balancing)
- United States v. Doswell, 670 F.3d 526 (4th Cir. 2012) (requiring district courts to balance releasee’s confrontation interest against government’s good cause before admitting hearsay at revocation hearings)
- United States v. Washington, 498 F.3d 225 (4th Cir. 2007) (supervising chemist may testify to review of machine-generated data when other technicians conducted tests)