Can a pathologist rely on another pathologist's autopsy report to determine cause of death?

California, United States of America


The following excerpt is from People v. Thongphun, G053338 (Cal. App. 2017):

The trial court eventually overruled defense counsel's objections, stating that People v. Dungo (2012) 55 Cal.4th 608 (Dungo), provided that a pathologist could rely on another pathologist's autopsy report to form his own independent opinion as to cause of death. Defense counsel argued Dungo was distinguishable because in Dungo, there was no testimony as to the actual autopsy findings. The trial court clarified that the autopsy report was not introduced in Dungo and there was no testimony from the examiner who prepared it. After further discussion, the court ruled the testimony admissible.

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