Laboratory reports have been held not admissible against the defendant in a criminal case under the public records exceptions.{footnote}U.S. v. Oates, 560 F.2d 45, 67-68 (2nd Cir. 1977) (applying FRE 803(8)(B) and (C) and finding government-employed chemist to be “other law enforcement personnel” under FRE 803(8)(B)).{/footnote}

Laboratory reports have been held admissible hearsay under the business records exception.{footnote}Lentz v. State, 604 So.2d 243, 248-49 (Miss. 1992){/footnote}