Parker v. Commonwealth

LARRY G. ELDER, Judge.

Timothy J. Parker (appellant) appeals from his jury trial conviction for maliciously causing bodily injury in violation of Code § 18.2-51. On appeal, appellant contends the admission of hospital records under the business records exception to Virginia’s hearsay rule violated his rights under the Sixth Amendment’s Confrontation Clause because the records included his report of how he sustained the injuries for which he was treated. We hold the trial court’s admission of the records was not error and affirm.

I

BACKGROUND

In December of 1999 or January of 2000, appellant’s…