Can Self-Authenticated, Certified Business Records Violate The Confrontation Clause? Federal Evidence Review, 30 July 2008.
Pointing to United States v. Hemphill, 514 F.3d 1350 (D.C. Cir. 2008), the reviewers posit that Fed. R. Evid. 902 (Mil. R. Evid.) leads to "testimony" in violation of Crawford v. Washington, 541 U.S. 36 (2004).