LA1: State cured error of SDT for medical records with SW showing independent source

Defendant was charged with rape of a minor and whether he transmitted chlamydia to the alleged victim was a fact issue in dispute. The state obtained the records by subpoena finding that he had been a carrier since 2010, but it should have used a search warrant. Defendant objected, the trial was continued, and the state applied for the records by search warrant without referring to the contents of the medical records. The search warrants were valid because the initial process was not used to charge defendant (compare State v. Skinner)–he was already charged and this was additional proof obtained by independent means. State v. Ford, 2017 La. App. LEXIS 1730 (La.App. 1 Cir. Sept. 27, 2017).