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The Supreme Court says: There is no Confrontation Clause exception for volunteered testimony, and by the way, these affidavits were prepared in response to a police request

Prosecuting attorneys argued that analyst affidavits don't trigger the Confrontation Clause because they were not prepared in response to interrogation.  The Court again essentially responded with a ‘so what', and stated there has never been a Confrontation Clause exception for volunteered testimony.  Justice Scalia went on to point out that the certificates in this case, as in all criminal cases, were prepared in response to a police request for use at trial.

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