Carter v. Commonwealth

Opinion

COLEM1AN, J.

Following a bench trial, Ronald Carter was convicted for distribution of cocaine in violation of Code § 18.2-248. On appeal Carter argues that the trial court erred: (1) by admitting into evidence a certificate of analysis despite the Commonwealth’s failure to prove compliance with the filing requirement of Code § 19.2-187; and (2) by allowing the clerk of the circuit court to testify about the filing in violation of Code § 19.2-271. We disagree with both arguments and affirm his conviction.

Carter contends that the certificate of analysis was not filed in compliance with…