Commonwealth v. Westbrooks

The defendant, Jack Westbrooks, appeals from convictions of four violations of the controlled substances act *418after a jury trial in Superior Court.1 Specifically, the defendant first complains that the admission of certificates of chemical analysis in the absence of testimony from the analyst violated his confrontation rights and was harmful error. While admission of the certificates was error, it was harmless beyond a reasonable doubt. Second, the defendant contends that the motion judge (who was not the trial judge) erred in denying the defendant’s motion to suppress the evidence obtained…