Was Court's Admission of Cell Phone Records at Trial Without Expert Authentication Unconstitutional? Under Sixth Amendment Right to Confront, Cross-Examine Witnesses

8th District Court of Appeals (Cuyahoga County)

ISSUE: Does a trial court violate a defendant's Sixth Amendment right to confront witnesses against him when it allows the state to introduce records documenting cell phone traffic of alleged co-participants in a crime without requiring authenticating testimony by an expert witness who can be cross-examined by defense counsel with regard to the reliability of the proffered records and the factual conclusions that can and cannot be drawn from them?