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Name: People v. Johnson
Case #: A105199
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 08/31/2004
Subsequent History: 11/10/04 rev. den.

Johnson appealed from a judgment sending him to prison for a probation violation, contending that the admission of a hearsay lab report at the revocation hearing violated his constitutional rights under Crawford v. Washington. The appellate court here disagreed and affirmed. A lab report is not testimonial hearsay under Crawford. The lab report was not a substitute for live testimony at the hearing, but routine documentary evidence.