Porter v. Cook County Sheriff’s Merit Board

Cook County Sheriff's Merit Board terminated Plaintiff's employment for testing positive for a cocaine metabolite. Even if testing lab's litigation package should not have been admitted, another lab's test results confirmed that Plaintiff tested positive for benzoylecgonine, and thus any error was harmless. Board did not abuse its discretion in admitting lab's litigation package under the business records exception. The alleged missteps in testing procedure did not affect validity of the lab results, were corrected, or were overcome by other evidence that Plaintiff tested positive. (LAVIN and COGHLAN, concurring.)