People v. Garcia

Defendant was convicted of driving while his driver’s license was revoked and was sentenced to 18 months in prison. He appealed and argued he was denied his constitutional right to confrontation by the admission of a certified copy of his driving abstract at trial. The appellate court affirmed, finding that the driving abstract certification did not set forth anyone’s personal knowledge of a fact necessary for the defendant’s conviction and, further, that it was not collected in anticipation of defendant’s prosecution. As a result, the appellate court concluded that its admission did not violate the defendant’s right to confrontation. (PUCINSKI and HYMAN, concurring)