Last week, the U.S. Supreme Court issued a ruling in Williams v. Illinois that departed from the Court’s recent trend of rulings that had been in favor of a defendant’s rights under the Confrontation Clause.
Williams was convicted of rape when his DNA was found to “match” DNA located on the victim’s vaginal swab. During the bench trial, the State presented expert testimony from Sandra Lambatos, a forensic specialist at the Illinois State Police lab. She testified that records showed Cellmark, a private lab, received vaginal swabs taken from the victim and created a DNA profile of the alleged offender. Lambatos then testified she compared this DNA profile to the one the state lab produced using Williams’ blood.
The defense moved to exclude Lambatos’ testimony to the extent that she relied on the DNA results produced by Cellmark. The State argued the defense’s ability to cross-examine Lambatos satisfied Williams’ Confrontation Clause rights and cited an Illinois rule of evidence that allows an expert to disclose facts on which her opinion is based even if she does not have first-hand knowledge of those facts. The trial court held that Lambatos’ testimony did not violate the Confrontation Clause as the report generated by Cellmark was not offered into evidence to prove Williams’ guilt.
In Crawford v. Washington, the Supreme Court held that the Confrontation Clause prohibited the admission of “testimonial” hearsay statements when the defendant had no opportunity to cross-examine the witness speaking against him. The Court defined a “testimonial” statement as one that, at the time it is made, can reasonably be expected to be used for purposes of a criminal prosecution. In two cases that followed, Melendez-Diaz v. Massachusetts and Bullcoming v. New Mexico, the Court expanded on Crawford and held that the contents of scientific reports could not be admitted into evidence unless the defendant was permitted to confront the analysts responsible for producing the reports. The Court reasoned that these reports contained “testimonial” statements made in order to prove a fact at trial. By contrast, in Williams, a majority of the Court found that the contents of the Cellmark report were not “testimonial” under Crawford.
The plurality, consisting of four justices, reasoned that the Cellmark report was not testimonial because it was submitted for a much more limited purpose than the forensic reports that were introduced in previous cases to prove a particular defendant’s guilt. The Cellmark report, by itself, did not prove Williams’ guilt as it was merely a report of a DNA profile. The significance of the Cellmark testing was not immediately apparent to technicians running the tests since, at the time, it had not been matched to a particular individual. Further, the fact that Cellmark returned a DNA profile that matched Williams demonstrated the lab’s reliability as the victim identified Williams in a line-up and at trial as her attacker.
Standing apart from the plurality, Justice Thomas found Lambatos’ expert testimony admissible because the Cellmark report lacked the requisite “formality and solemnity” of such materials as depositions, affidavits, or prior testimony to be considered “testimonial.” He concluded the report was not a statement by a “witness” against the defendant as it was neither a sworn nor a certified declaration of fact.
As the narrowest opinion, Justice Thomas’ reasoning will bind lower courts assessing whether forensic reports are testimonial. Still, it is not entirely clear how lower courts will interpret this ruling, indicating the possibility of further examination by the High Court in the future.
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