Francisco Martinez Garcia, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' judgment that an autopsy report prepared by a deputy medical examiner is admissible as a public record under Tex.R.Crim.Evid. 803(8)(B), holding that medical examiners are not "other law enforcement personnel". The Court applied the two‑prong test from Cole and concluded the report is both objective and prepared by officials without an inherent motive to distort results. Justice Maloney dissented, arguing the report should be excluded as hearsay.