Mojica Phipps v. State
In a drug trafficking prosecution, the State's two testifying analysts merely read the weight of the controlled substances off reports prepared by non-testifying FDLE chemists, without personal knowledge or independent expert opinion as to weight. The majority assumed any hearsay error was harmless given other unobjected-to testimony about weight and nature of the drugs, and affirmed the convictions; Judge Cohen dissented, finding the admission erroneous and the error not harmless because the State's 'other evidence' (a confidential purchase negotiated for a presumed amount) only established presumed, not measured, weight.
Key facts
- Mojica Phipps was prosecuted for drug trafficking based on controlled substances seized during an investigation.
- The State's two testifying analysts read drug weights from reports prepared by non-testifying FDLE chemists, without personal knowledge or independent expert analysis of the weight.
- +2 more key facts with a free trial
Why it matters
This opinion highlights a recurring evidentiary trap in drug trafficking prosecutions: using an analyst to simply read weight figures from a non-testifying chemist's report, rather than presenting the original tester or… — full analysis with a trial
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