SCOTUS 6-19-2012

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by: Iahmad • June 19, 2012 • no comments

Right to Confront Witnesses Only Applies for Testimony For the Truth of the Matter Asserted >> Defendant Did Not Have Right to Confront Witnesses About Source of DNA Comparison

In a plurality opinion, the Supreme Court addressed the issue of expert testimony and the Confrontation Clause in upholding a conviction based on a DNA profile linking the defendant to the crime.

In Williams, an expert in a rape trial testified that there was a match between a DNA profile report of the defendant and the victim's vaginal swab, both of which were produced by an outside lab. The state presented other evidence to show the relevance of the match, which indicated that the report was based on a forensic sample taken from the scene of the crime. The defendant argued that because no one from the outside lab testified about the DNA profiling process or to the fact that the semen came from the vaginal swab and the expert did not have personal knowledge of the DNA profiling process, his confrontation rights were violated.

The plurality held that the expert's testimony did not violate the Confrontation Clause because the provision only applies to statements offered to prove the truth of the matter asserted. The DNA report was not considered for the truth, but only for the limited purpose of determining whether the two DNA profiles matched. Thus, the trier of fact could determine how much weight to give to the expert testimony.

The plurality also stated that even had the outside DNA profile report been admitted into evidence, it would not have violated the Confrontation Clause because the profile report was not produced to obtain evidence against a particular defendant.

In his concurrence, Justice Thomas concluded that the statements relied upon by the expert were introduced for the truth. Nevertheless, he upheld the conviction because the DNA report did not have the requisite formality to be considered testimonial for purposes of the Confrontation Clause.

Williams v. Illinois (2012)