Taylor v. Commonwealth

BENTON, Judge, with whom ELDER, Judge,

joins, dissenting.

At trial, the Commonwealth sought to admit a certificate of analysis pursuant to Code § 19.2-187. In pertinent part, that statute reads as follows:

In any hearing or trial of any criminal offense ..., a certificate of analysis of a person performing an analysis ... *13performed in any laboratory operated by the ... the Division of Forensic Science when ... such certificate is duly attested by such person, shall be admissible in evidence as evidence of the facts therein stated and the results of the analysis or examination referred to…