State v. Burrow, 366 N.C. 326 (Dec. 14, 2012)

The court vacated and remanded State v. Burrow, 218 N.C. App. 373 (Feb. 7, 2012), after allowing the State’s motion to amend the record to include a copy of the State’s notice under G.S. 90-95 indicating an intent to introduce into evidence a forensic report without testimony of the preparer. In the opinion below, the court of appeals had held that the trial court committed plain error by allowing the State to admit a SBI forensic report identifying the substance at issue as oxycodone when neither the preparer of the report nor a substitute analyst testified at trial.