State v. Best
In State v. Best, 146 Ariz. 1, 703 P.2d 548 (App. 1985), the Court followed the lead of several circuit courts finding the "law enforcement personnel" exclusion in Rule 803(8)(B) is primarily aimed at observations made by police officers in adversarial roles, for example, when officers are investigating crime scenes or apprehending suspects.
In Best, the Court ruled that a laboratory report by a deceased fingerprint examiner that detailed where particular fingerprints had been lifted was admissible and not excluded under Rule 803(8)(B). 146 Ariz. at 4, 703 P.2d at 551.
The Court stated:
Lifting and recording is, for a fingerprint examiner, the type of routine daily task that has always been thought to be reliably done under both the business and official records exceptions to the hearsay rule; the adversarial, confrontational risk of misperception and misrecording present at an arrest of a criminal at the scene of the crime is about as far removed from this routine exercise in a police laboratory as it is possible to imagine. Id.