Michels v. Commonwealth

FITZPATRICK, Judge.

Robert Michels (appellant) appeals his conviction by a jury of three counts of obtaining money by false pretenses in violation of Code § 18.2-178. He argues that the introduction of documents from the Delaware Secretary of State, which certified that two entities were not corporations licensed in Delaware, violated his Sixth Amendment rights. He contends that because such records were “testimonial hearsay,” his rights guaranteed to him by the Confrontation Clause were violated when the documents were introduced at trial without a showing that the Delaware Secretary of State…