context: In effect, the certification is doubly removed from a right of confrontation. It constitutes a nontestimonial authentication of records of nontestimonial information.
citation_a.signal: see also
citation_a.identifier: 459 Mass. 775, 784
citation_a.parenthetical: record certifying the working condition of police breathalyzer machinery "rather than reflecting 'judgment and discretion' or 'expressions of opinion' of . . . [a] technician, merely signifies that the . . . procedures prescribed by regulation were satisfactorily performed"
citation_a.sentence: See also Commonwealth v. Zein-inger, 459 Mass. 775, 784 (2011) (record certifying the working condition of police breathalyzer machinery “rather than reflecting ‘judgment and discretion’ or ‘expressions of opinion’ of . . . [a] technician, merely signifies that the . . . procedures prescribed by regulation were satisfactorily performed”).
citation_b.signal: see
citation_b.identifier: 460 F.3d 920, 927
citation_b.parenthetical: "[gjiven [that hospital] records themselves do not fall within the constitutional guarantee provided by the Confrontation Clause, it would be odd to hold that the foundational evidence authenticating the [hospital] records do[es]"
citation_b.sentence: See United States v. Ellis, 460 F.3d 920, 927 (7th Cir. 2006) (“[gjiven [that hospital] records themselves do not fall within the constitutional guarantee provided by the Confrontation Clause, it would be odd to hold that the foundational evidence authenticating the [hospital] records do[es]”).