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Name: People v. Morris
Case #: A119162
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 08/27/2008

CLETS rap sheets are not testimonial and their admission is permissible under Crawford v. Washington. During his trial for grand theft, the trial court admitted a CLETS rap sheet as proof of Morris’s alleged prison priors. On appeal, Morris contended that the admission of the rap sheet violated his Sixth Amendment right to confrontation, citing Crawford. The appellate court rejected the argument, finding that the court in People v. Taulton (2005) 129 Cal.App.4th 1218 was correct in holding that rap sheets are not testimonial hearsay and their admission, therefore, does not violate the right to confront and cross-examine witnesses under Crawford. The statements contained in rap sheets are not statements of the type addressed in Crawford because they are merely compilations of statistical data and do not communicate facts about the underlying criminal activity.