Michael Tyrone Morgan v. Commonwealth of Virginia

CLEMENTS, Judge.

In a bench trial, Michael Tyrone Morgan (appellant) was convicted of possessing with the intent to distribute more than five pounds of marijuana in violation of Code § 18.2-248.1, and simultaneously possessing a firearm and more than one pound of marijuana in violation of Code § 18.2-308.4. On appeal, appellant argues the trial court erred in admitting into evidence the certificates of analysis pertaining to the drugs and firearm seized by the police. He contends admission of the certificates violated his Sixth Amendment right to confront the evidence against him. Appellant…