U.S. v. Turner

On remand from U.S. Supreme Court, Ct. of Appeals found that Dist. Ct. violated defendant’s rights under Confrontation Clause by admitting testimony from supervisor that subordinate had followed standard testing procedures in reaching conclusion that substance that defendant had distributed to police contained cocaine base since supervisor’s testimony concerned matters that were solely within subordinate’s knowledge. However, any error was harmless given other evidence such as cost and description of substance that indicated that substance was cocaine base. Moreover, supervisor could properly give expert opinion that said substance was cocaine base based upon data produced by subordinate’s testing of substance.