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Appeals court hears confrontation-clause challenge to gunshot-residue evidence in Robert Holland case

Appellate Court (panel) · January 14, 2026
AI-Generated Content: All content on this page was generated by AI to highlight key points from the meeting. For complete details and context, we recommend watching the full video. so we can fix them.

Summary

At an appellate argument, defense counsel asked judges to vacate Robert Holland's murder conviction, arguing Agent Anderson improperly relayed another agent's gunshot-residue analysis in violation of the Sixth Amendment confrontation clause; the state said the issue was waived and pointed to GPS, video and the recovered firearm as dispositive evidence.

An appellate panel on Jan. 15 heard argument over whether testimony about a gunshot-residue (GSR) analysis violated the Sixth Amendment confrontation clause in the conviction of Robert Holland for a Dec. 8, 2021, murder.

Defense attorney Mitch Raines told the court he represented Holland and limited oral argument to the confrontation-clause claim. Raines said Agent Anderson of the Tennessee Bureau of Investigation testified not from her own independent testing but by reviewing and "checking the math" from the work of another agent, Agent Davis, and that trial counsel objected when it appeared Anderson was testifying to someone else's analysis. "The objection began with trial counsel saying that it was informed that the state was…

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