In Bullcoming v. New Mexico, 564 U.S. 647 (2011) defendant was arrested for driving while intoxicated and a sample of his blood was taken pursuant to a warrant and analyzed by a state laboratory forensic analyst. At trial it was revealed that the analyst had been placed on unpaid leave for undisclosed reasons. His report was admitted as a business record and another analyst, familiar with testing device and laboratory procedures, was called to testify. The defendant's blood sample was sent to a state lab for testing after he was arrested for drunk driving. The analyst recorded the results on a state form and signed the form, which included a "'certificate of analyst.'" A reviewer certified that the analyst was qualified and that established procedures had been followed. At Bullcoming's trial, the analyst who tested his blood sample did not testify because he had been placed on disciplinary leave. The prosecution called another analyst who was familiar with the lab's testing procedures but had not signed the certification, nor had he participated in, observed, or reviewed the analysis of Bullcoming's sample. The plurality opinion in Bullcoming explained that the surrogate analyst was an inadequate substitute for the analyst who performed the test. Surrogate testimony by someone who is qualified as an expert regarding the machine used and the lab's procedures could not convey what the actual analyst knew or observed and would not expose "any lapses or lies" by the certifying analyst. The court stated that, if the Sixth Amendment is violated, "no substitute procedure can cure the violation." In Bullcoming v. New Mexico, analyst Curtis Caylor's report certified that "he received Bullcoming's blood sample intact with the seal unbroken, that he checked to make sure that the forensic report number and the sample number 'corresponded,' and that he performed on Bullcoming's sample a particular test, adhering to a precise protocol." Id. at , 131 S. Ct. at 2714. Additionally, Caylor certified that "no 'circumstance or condition . . . affected the integrity of the sample or . . . the validity of the analysis.'" Id. At the time of trial Caylor had been placed on unpaid leave and, in his place, the state relied upon the testimony of Gerasimos Razatos, an analyst who worked for the same laboratory as Caylor, but "had neither observed nor reviewed Caylor's analysis." Id. at , 131 S. Ct. at 2711-12. The state never asserted Razatos had developed an independent opinion on the results of the forensic testing. Id. at , 131 S. Ct. at 2716. The Court concluded Razatos's testimony violated Bullcoming's Confrontation Clause right. Id. at , 131 S. Ct. at 2714-15. In doing so, the Court found Razatos only provided "surrogate testimony," which "could not convey what Caylor knew or observed about the events his certification concerned . . . or expose any lapses or lies on the certifying analyst's part." Id. at , 131 S. Ct. at 2715. And Bullcoming could not cross-examine Caylor about the reason he had been placed on unpaid leave or any other facts that may have raised doubts about the certifying analyst's credibility. Id. at , 131 S. Ct. at 2715-16. "In short, when the State elected to introduce Caylor's certification, Caylor became a witness Bullcoming had the right to confront." Id. at , 131 S. Ct. at 2716.