AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The State appealed a district court order requiring it to call the forensic pathologist who performed an autopsy as a witness or have all evidence from the Lubbock coroner's office suppressed. The appeal concerns the admissibility of statements from the autopsy in the context of the Confrontation Clause.

Procedural History

• District Court of Eddy County, Jane Shuler-Gray, District Judge: Ordered that the State must call the forensic pathologist as a witness or have evidence from the Lubbock coroner's office suppressed.

Parties' Submissions

• Plaintiff-Appellant (State): Argued that Dr. Natarajan would not be relying on the subjective observations of Dr. Shrode but making his own independent determination of the cause of death and injuries based on the photographs, microscopic glass slides, autopsy report, and extensive ante mortem medical documentation.
• Defendant-Appellee (Curtis Jones): Contended that by ruling Dr. Shrode had to be present, the district court implicitly rejected the State’s argument that Dr. Natarajan was merely looking at raw data produced in the autopsy.

Legal Issues

• Whether the district court erred in requiring the State to call the forensic pathologist who performed the autopsy as a witness for the evidence from the Lubbock coroner's office to be admissible.
• Whether the statements at issue are testimonial and thus subject to the requirements of the Confrontation Clause.

Disposition

• The Court of Appeals reversed the district court's order and remanded for the district court to consider whether the statements at issue are testimonial.

Reasons

• J. MILES HANISEE, Judge, with JAMES J. WECHSLER, Judge, and MICHAEL D. BUSTAMANTE, Judge concurring, found that the district court did not conduct a full inquiry required to determine a Confrontation Clause violation. The Court of Appeals based its decision on the Supreme Court's decision in State v. Navarette, which clarified that not all material within an autopsy file is testimonial and inadmissible. The appellate court concluded that the district court's order focused only on the availability of the witness, without fully analyzing whether the expert would be relying on and conveying testimonial statements made by another forensic pathologist. The appellate court remanded the case for the district court to explicitly rule on whether Dr. Natarajan would only be relying on raw data and to make a determination on the testimonial nature of the information at issue (paras 1-4).