Appeals Court, August 15, 2013

Erroneously admitting a drug certificate without trial testimony from the chemical analyst, may be considered harmless error when an on-site field test, supported by the requisite foundation, is combined with corroborative and circumstantial evidence identifying the substance’s composition.

In this case, the court held that erroneously admitting the drug certificates for the drugs seized during four controlled buys was harmless error because of the field tests, conducted after each transaction, coupled with corroborating evidence and testimony that indicated the substance was cocaine. Conversely, the erroneously admitted drug certificate for the substance found in the defendant’s home, during a search warrant, was not harmless beyond a reasonable doubt because there was no field test or corroborating evidence of the substance’s composition.