Addresses public health consequences of laws creating criminal liability for accidental drug overdose and provides research supporting the following conclusions:
Motions and Briefs
Appellant Reply Brief in State v. Anderson
Addresses defendant’s motion to dismiss where evidence on causation was insufficient, failure to instruct the jury on intervening acts of others, failure to instruct the jury on lesser included offense of involuntary manslaughter when the evidence of malice was in conflict, and court’s failure to intervene in state’s closing argument. Reply Brief filed in June …
Appellant Brief in State v. Anderson
Appellant’s Brief addressing trial court’s denial of defendant’s motion to dismiss where the state did not prove the defendant’s actions proximately caused the decedents’ deaths and another individual’s actions were a superseding cause of the decedents’ deaths which broke the chain of causation. Also addresses trial court’s failure to instruct on whether intentional acts by …
Appellant Brief in State v. McCrorey
Addresses complex chain of causation, proximate cause, identify of the controlled substance, and cause of death. Brief filed in Aug. 2023 in 2020 case.
Notice of Objection
Sample notice of objection to the admission of lab report without the testimony of the chemical analyst
Bridges Amicus Brief
Filed by the Innocent Network in support of the defendant.
Bridges Motion for Appropriate Relief Consent Order
Defendant-Appellant’s Brief: State v. Lance
Example Facebook Search Warrant and Non-Disclosure Order
Example Subpoena Language for Call Detail Records
Example Discovery Items Pertaining to Mobile Device, Computers, and Cloud Service Forensics
Sample Motion Requesting Disclosure of SCL Analyst Certification Results
Sample Motion to Preserve Evidence for Analyst Certifications
This sample motion contains a request for specific discovery, motion to preserve evidence and motion to produce for an in camera inspection by the court is another approach.
Sample Motion to Preserve Evidence for Analyst CertificationsRead More
Motion to Release SCL Analyst Certification Information, Buncombe County, 06/12/12
June 12, 2012 State’s Motion requesting information regarding State Crime Lab certification exams. No file stamped version is available.
Motion to Release SCL Analyst Certification Information, Buncombe County, 06/12/12Read More
Continuance Order, Buncombe County, 06/13/12
Hearing regarding SCL analyst certification results has been continued to June 26, 2012 at 2 pm.