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

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' judgment that the autopsy report was admissible as a public record under Rule 803(8)(B) because medical examiners are not "other law enforcement personnel" and the report is not inherently unreliable. The Court applied the two‑prong test from Cole, finding the reports objective and the medical examiner's office non‑adversarial. A dissent argued the report should be excluded as a law‑enforcement record and would have reversed the judgment.