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under such circumstances, as the holding in Bullcoming might not be so broad as to make it applicable to ‘a case in which the person testifying is a supervisor, reviewer, or someone else with a personal, albeit limited, connection to the scientific test at issue.’ Id. at 2722 (Sotomayor, concurring). Here, Pickens was the supervisor, she drafted the report, and had a substantial personal connection to the scientific test at issue (having actually performed the vast majority of the testing herself).” Accord, Leger v. State , 291 Ga. 584, 732 S.E.2d 53 (October 1, 2012) (testifying lab supervisor directed the testing but didn’t perform it herself; her testimony properly admitted). Hite v. State, 315 Ga.App. 221, 726 S.E.2d 704 (March 27, 2012). DUI conviction affirmed; standard State Patrol record setting forth purpose for roadblock wasn’t testimonial, distinguishing Bullcoming v. New Mexico , 09-10876, ___ U.S. ___, 131 S.Ct. 2705, 180 L.Ed.2d 610, 2011 WL 2472799 (2011). “Unlike an analyst's report of tests done and conclusions drawn, … the Roadblock Form in this case is a record of supervisory approval for the establishment of a roadblock for certain stated purposes. The testimony established that the form is created for the administration of the State Patrol's affairs, as it is prepared in every case of a road block, presumably for recordkeeping purposes. The fact that the form can be used in court, with an additional stamped certification from a custodian of records …, does not change the primary purpose of the form from administrative to testimonial.” Forrester v. State, 315 Ga.App. 1, 726 S.E.2d 476 (March 19, 2012). Physical precedent only. Forgery convictions reversed; evidence didn’t support finding that the money orders in question were counterfeit. “[T]he only evidence introduced at trial to demonstrate that the money orders were counterfeit were copies of the processed orders themselves, each bearing a stamp reading, ‘Payment Stopped Counterfeit.’ which the State proffered under the business records exception to the hearsay rule, OCGA § 24–3–14(b).” State presented witness from bank who testified to bank procedure; she testified that the “Counterfeit” stamp would have been entered by the financial institution on which the money order was drawn. Not only does this not lay a proper business record foundation for the “Counterfeit” stamp, it violates defendant’s confrontation rights. “‘The “central concern” of the Confrontation Clause is “to ensure the reliability of the evidence against a criminal defendant by subjecting it to rigorous testing in the context of an adversary proceeding before the trier of fact.” Maryland v. Craig, 497 U.S. 836, 845 (110 S.Ct. 3157, 111 L.Ed.2d 666) (1990).’ [ Miller v. State, 266 Ga. 850, 472 S.E.2d 74 (1996)]. To allow the admission of the stamp on the money orders as proof that they were indeed counterfeit would deprive Forrester of her right to conduct a thorough and sifting cross-examination on the determination that the money orders were counterfeit. Allowing the admission of such evidence would also relieve the State of its burden of proving that Forrester lacked the authority to possess and deliver the money orders, instead impermissibly shifting the burden to her to prove the money orders were not counterfeit, a burden she would have to undertake without full knowledge of the evidence against her. For example, the State presented no evidence showing how the determination of counterfeitness was made or identifying the factors that the institution relied upon in making that determination. [fn] See Id. at 856(7).” Query how this entry on a negotiable instrument is “testimonial” (vs. being merely hearsay) as discussed in Crawford, Melendez-Diaz, or other post-Crawford Confrontation cases, as it a) involves no state actor and b) would seem to have been made more for purposes of a commercial transaction that a criminal prosecution. Bowling v. State, 289 Ga. 881, 717 S.E.2d 190 (October 17, 2011). Murder and aggravated assault convictions affirmed; seizure of defendant’s hospital medical records by search warrant, and use thereof at trial, didn’t violate defendant’s rights under the Confrontation Clause. “[N]one of the medical records are testimonial inasmuch as the circumstances surrounding their creation and the statements and actions of the parties objectively indicate that the records were prepared with a primary purpose of facilitating Bowling's medical care. [ Michigan v. Bryant , 562 U.S. 344, 131 S.Ct. 1143, 1156(III), 179 L.Ed.2d 93 (February 28, 2011).] The records were created by medical personnel in connection with treatment rendered to Bowling in an emergency situation and are devoted to documenting and assessing Bowling's medical history and condition and describing his treatment. As to the drug and urine screens, Bowling's physician testified that she ordered the tests for medical purposes. Medical records created for treatment purposes are not testimonial. See Melendez–Diaz v. Massachusetts, [557 U.S. 305, 129 S.Ct. 2527, 2533 n. 2, 2542, 174 L.Ed.2d 314 (June 25, 2009)] (holding that affidavits of state laboratory analysts reporting results of chemical analysis of seized substance were testimonial but stating that “medical reports created for treatment purposes ... would not be testimonial under our decision today”); Massachusetts v. Dyer, 934 N.E.2d 293, 298–299 (Mass.Ct.App., 2010) (admission of medical records revealing defendant's blood alcohol level did not violate Confrontation Clause).” Accord, Hartzler v. State , 332 Ga.App. 674, 774 S.E.2d 738 (June 30, 2015); Samuels v. State , 335 Ga.App. 819, 783 S.E.2d 344 (February 25, 2016) (emergency room records used in DUI prosecution). Bullcoming v. New Mexico, 09-10876, ___ U.S. ___, 131 S.Ct. 2705, 180 L.Ed.2d 610, 2011 WL 2472799 (June 23, 2011). In DWI prosecution, trial court violated defendant’s Confrontation Clause rights by admitting into evidence
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