Is there any case law where a defendant has a right to confront a witness?

Even if this issue were not forfeited by Sastini's failure to assert an objection based on his right to confrontation, it is without merit. Some limited varieties of hearsay evidence are admissible without violating a defendant's right to confrontation. Despite its hearsay character, documentary proof of a prior conviction does not violate a right to confrontation. (People v. Lizarraga (1974) 43 Cal.App.3d 815, 820.)

"[T]he need for confrontation is particularly important where the evidence is testimonial, because of the opportunity for observation of the witness's demeanor. [Citation.] Generally, the witness's demeanor is not a significant factor in evaluating foundational testimony relating to the admission of evidence such as laboratory reports, invoices, or receipts, where often the purpose of this testimony simply is to authenticate the documentary material, and where the author, signator, or custodian of the document ordinarily would be unable to recall from actual memory information relating to the specific contents of the writing and would rely instead upon the record of his or her own action." (People v. Arreola (1994) 7 Cal.4th 1144, 1157.)