People v. Matthews

Defendant was convicted, after jury trial, of unlawful delivery of a controlled substance. Evidence was not closely balanced. Officer, prior to controlled drug buy, searched the confidential source and provided him with prerecorded funds. Source drove to the buy location with officer in front passenger seat. Improper hearsay testimony did not severely threaten to tip scales of justice against Defendant. Defendant failed to meet his burden to show disclosure of source's identity was necessary to prepare his defense. Defendant does not have an absolute right to learn identity of a confidential source. Even if court erred in allowed jury to view surveillance video of drug buy during deliberations, in response to jury note asking to see video which had been played during trial, alleged error does not rise to level of structural error, and did not affect fairness of trial and did not challenge integrity of judicial process. (TURNER and HARRIS, concurring.)