Proctor v. Commonwealth

Opinion

WILLIS, J.

Richard Proctor, appellant, was convicted by a jury of distribution of cocaine and of distribution of cocaine in a “drug-free zone.” He contends that the trial court erred in admitting into evidence an unauthenticated photocopy of a certificate of laboratory analysis. We agree and reverse the decision of the trial court.

Detective Kenneth Ray Giles testified that he took an envelope containing a white rock-like substance to the laboratory for analysis. He testified, without objection, that the two sheets of paper marked Commonwealth’s Exhibit 3 were the results he received…