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merchants, each merchant routinely generated a business record of the purchase and transmitted the record to the appropriate credit card company, which relied upon the transmitted record to routinely generate as its own business record the credit card statement sent to the purchaser for payment. The foundational testimony given by the credit card company representatives showed that they had sufficient knowledge of the manner in which the merchants and the credit card companies routinely generated these business records and functioned in this context as related businesses. We find no error in the trial court's conclusion that the credit card purchases transmitted by the merchants to the credit card companies were also business records of the credit card companies that were admissible under OCGA § 24–3–14 based on the foundational testimony given by the company representatives. Jackson v. State, 209 Ga.App. 217, 218–219, 433 S.E.2d 655 (1993); Moore v. State, 154 Ga.App. 535, 538–540, 268 S.E.2d 706 (1980).” Harper v. State, 300 Ga.App. 757, 686 S.E.2d 375 (November 5, 2009). In defendants’ trial for armed robbery and related charges, trial court properly admitted jail receipt for co-defendant Williams’s clothing as a business record despite witness’s lack of personal knowledge of the items. “The sheriff's office chief investigator, whose duties included overseeing the operations of the jail where Williams was transported upon his arrest, testified that when any suspect was booked, standard procedure required the collection of the suspect's personal clothing and the issuance of a uniform to the individual. The chief investigator further explained how the collected items were then stored and secured. Another investigator, who also was familiar with the procedure for booking individuals, testified that personal clothing was routinely collected from suspects during booking and then stored; that in the normal course of business, the jail created and maintained property receipts listing the personal clothing items collected from each booked suspect and further specifying the location of an inmate's stored items. Through this witness, the state introduced in evidence, pursuant to the business records exception, property receipts that itemized the personal property collected when Williams and the other defendants were booked.” “The investigators' testimony provided an adequate foundation for the admission of the property receipts, which were properly admitted under the business records exception.” “See Manley v. State, 284 Ga. 840, 844(1) n. 3 (672 S.E.2d 654) (2009) (property receipt, which specified the location from which a certain knife had originally been seized, was properly admitted under the business records exception); see also Hurst v. State, 285 Ga. 294, 297(3) (676 S.E.2d 165) (2009) (testifying witness need not be the custodian of records to provide foundation for admission under business records exception, and any lack of independent recollection on testifying officer's part regarding creation of fingerprint card, considered a business record, went only to weight of evidence, not to its admissibility).” Melendez-Diaz v. Massachusetts, 557 U.S. 305, 129 S.Ct. 2527, 174 L.Ed.2d 314 (June 25, 2009). Reversing Massachusetts Court of Appeals, a 5-4 majority finds that crime lab analyst’s certificates of drug test results was improperly admitted into evidence in violation of defendant’s Confrontation Clause rights under Crawford . “The certificates reported the weight of the seized bags and stated that the bags ‘[h]a[ve] been examined with the following results: The substance was found to contain: Cocaine.’” “[T]he certificates were admitted [over objection] pursuant to state law as ‘prima facie evidence of the composition, quality, and the net weight of the narcotic ... analyzed.’” “The documents at issue here, while denominated by Massachusetts law ‘certificates,’ are quite plainly affidavits: ‘declaration[s] of facts written down and sworn to by the declarant before an officer authorized to administer oaths.’ Black's Law Dictionary 62 (8th ed., 2004). They are incontrovertibly a ‘“solemn declaration or affirmation made for the purpose of establishing or proving some fact.”’ Crawford, supra, at 51, 124 S.Ct. 1354 (quoting 2 N. Webster, An American Dictionary of the English Language (1828)). The fact in question is that the substance found in the possession of Melendez-Diaz and his codefendants was, as the prosecution claimed, cocaine – the precise testimony the analysts would be expected to provide if called at trial. The ‘certificates’ are functionally identical to live, in-court testimony, doing ‘precisely what a witness does on direct examination.’ Davis v. Washington, 547 U.S. 813, 830, 126 S.Ct. 2266, 165 L.Ed.2d 224 (2006) (emphasis deleted).” Note, “we do not hold, and it is not the case, that anyone whose testimony may be relevant in establishing the chain of custody, authenticity of the sample, or accuracy of the testing device, must appear in person as part of the prosecution's case.” Majority rejects a number of arguments from defendant and from dissent (Kennedy, writing for Roberts, Breyer and Alito): that the lab analysts here are not “accusatory” witnesses; that they are not “conventional” or “typical” witnesses; that scientific evidence does not implicate the Confrontation Clause; that the certificates here are admissible at common law as business records; that the defendant could have subpoenaed the witness if he wanted; and finally, that the “necessities of trial” warrant relaxing the requirements of the Confrontation Clause in this instance. Cites a Georgia case, Miller v. State , 266 Ga. 850, 854-855, 472 S.E.2d 74, 78-79 (1996), and a Georgia statute, OCGA § 35-3-154.1, among other state authority, as examples of a constitutionally-permissible approach to the practical logistical challenge of presenting lab witnesses live at trial, one “requiring the defendant to give early notice of his intent to confront the analyst.” Majority rejects dissent contention that this is “burden-shifting”: “It is common to require a defendant to exercise his rights under the Compulsory Process Clause in advance of trial, announcing his intent to present certain witnesses. [Cits.] There is no conceivable reason why he cannot similarly be compelled to exercise his

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