Cold Case murder conviction did not violate the Confrontation Clause by admitting an autopsy report without testimony from the pathologist

In 2013, defendant James L. Mayfield was convicted of the murder of Jenny  Read in a 1976 cold case in San Francisco. Read’s body was found with multiple stab wounds and her pants partially removed. There was the presence of sperm on her body. In 2009, some of the evidence in this case was re-tested and a sperm sample was found to match the DNA of Mayfield in a DNA database. An unknown third party DNA sample was also found on the evidence, and while this likely could have been attributed to flaws in the evidence collection techniques at the time of the crime or simply an error in the amplification process of the DNA, there was also the possibility that another assailant was also involved in the attack. Mayfield was subsequently interviewed and denied any knowledge or involvement with the crime. He voluntarily provided a saliva sample to law enforcement officials and was subsequently arrested for the crimes.

After his conviction, he contested the admission of a prior rape conviction at trial and the admission of a redacted autopsy report in which the pathologist who prepared the report had since died. The court ruled that the admission of the prior rape conviction was not an abuse of discretion and the error, if any, would have been harmless. As for the autopsy report, the diagnosis and cause of death had been redacted. The autopsy report was used primarily to show the collection of samples and specimens as well as observations about the victim’s body at the time of the. According to the court, the Confrontation Clause had not been violated, citing People v. Dungo: “[S]tatements in an autopsy report describing a nontestifying pathologist’s observations about the condition of the victim’s body are not testimonial because the ‘primary purpose’ of recording such facts does not relate to a criminal investigation. [Citation.] [The court] also described these statements, which ‘merely record objective facts,’ as being ‘less formal than statements setting forth a pathologist’s expert conclusions’ about the victim’s cause of death.”  Additionally, because the autopsy report showed compliance with standard procedure at the time the evidence was collected, there was also no chain of custody issue. The court affirmed Mayfield’s conviction.

People v. Mayfield, 2015 WL 7257985 (2015).

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