State v. Brennan, 203 N.C. App. 698 (May. 4, 2010)

Applying Locklear and Mobley, both discussed above, the court concluded that testimony of a substitute analyst identifying a substance as cocaine base violated the defendant’s confrontation clause rights. The court characterized the substitute analyst’s testimony as “merely reporting the results of [non-testifying] experts.” Rather than conduct her own independent review, the testifying analyst’s review “consisted entirely of testifying in accordance with what the underlying report indicated.” For more discussion of this case, see the blog post.