State of Idaho v. Heriberto Sandoval-Tena

Summary

The Supreme Court of Idaho held that a state police crime laboratory report was improperly admitted under the business-records exception because it was also excluded from the public-records exception when offered by the prosecution. The court deemed the evidentiary error harmless because the forensic technician testified to the report's contents. It also held that the trial judge's comments to the prosecutor outside the jury's presence and the recall of the witness did not constitute reversible error, and affirmed the conviction.

Holdings

1. The police crime-laboratory report was not admissible under the business-records exception. Because the report was an investigative report prepared by law-enforcement personnel and offered by the government in a criminal case, it was also excluded from the public-records exception under I.R.E. 803(8).
2. Admission of the laboratory report was harmless error and did not require reversal.
3. The trial judge did not commit reversible error by informing the prosecutor outside the jury's presence that the weight testimony had not been elicited and then permitting the State to recall the technician. The denial of the mistrial motion was proper.

Questions Presented

1. Whether the police crime-laboratory report was admissible under Idaho Rule of Evidence 803(6), the business-records exception to the hearsay rule.
2. Whether admission of the laboratory report, even if erroneous, was prejudicial.
3. Whether the trial judge's comments to the prosecutor about the omitted weight testimony and the subsequent recall of the laboratory technician constituted reversible error or required a mistrial.

Disposition

affirmed