(Private) From Report to Cross-Examination: Working With Alternate Matrix Drug Test Results for Cuyahoga County, OH PDO
Results from alternate testing matrices — hair, oral fluid, and sweat — can be difficult to interpret, and the reports issued by testing laboratories rarely explain their own limits. This presentation begins where a foundational overview of the matrices ends: what an attorney does once one of these results is in the case file. It reviews the discovery necessary to evaluate a result, the methods and procedures used by the laboratories that perform this testing, the advantages and disadvantages of each matrix, and the questions that separate what a result establishes from what it is being offered to prove. Sample cross- examination questions are provided for each matrix. Because hair and sweat testing appear most often in family court and child custody matters, those settings are addressed alongside criminal applications.
Highlights (5-10 mins, each section)
1. Review of Drug Testing Matrices — what each sample type can and cannot establish
2. Necessary Discovery — collection records, chain of custody, laboratory SOPs, and underlying analytical data
3. Testing Laboratories and Procedures — screening versus confirmation, cutoffs, and
accreditation
4. Advantages and Disadvantages by Matrix — detection windows, external contamination, and tampering
5. Cross-Examination Questions — sample questions organized by matrix and method
6. Common Attorney Challenges — interpretation beyond what the data supports
Objectives
Upon completion of this course, the attendee will:
1. Identify the discovery needed to evaluate an alternate matrix result, including collection
records, chain of custody, laboratory procedures, and underlying data.
2. Describe the analytical methods used by laboratories that test hair, oral fluid, and sweat, and the reporting limits that apply to each.
3. Recognize the advantages and limitations of each matrix, including detection windows, external contamination, and susceptibility to tampering.
4. Formulate cross-examination questions appropriate to the matrix and method at issue.
5. Distinguish between what a laboratory result establishes and the interpretation offered of it.
Speaker
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Blake Stutzman




