Timothy Brian Cole, Appellant v. the State of Texas, Appellee

Summary

The Court reversed the Court of Appeals and remanded, holding that the chemist’s reports were matters observed by law‑enforcement personnel and thus inadmissible under TRCE 803(8)(B), and that TRCE 803(6) does not provide a back‑door admission for such reports. Justice McCormick dissented, arguing the reports should be admissible under the business‑records exception, and Justice Maloney concurred, noting the need to address the chemist’s expert testimony under Rules 703 and 705.