Summary
The United States Supreme Court affirmed the Illinois Supreme Court’s judgment in a rape case involving expert testimony about a DNA profile produced by an outside laboratory. The Court held that the expert’s testimony did not violate the Confrontation Clause because the referenced statements were not offered for their truth, and alternatively concluded that the laboratory report was not testimonial under the plurality’s analysis. Justice Thomas concurred in the judgment, while Justice Kagan dissented.
Topics
Practice areas
Questions Presented
- Whether the Confrontation Clause bars a prosecution expert from testifying to an opinion based on facts or data supplied by a nontestifying laboratory when the underlying report is not admitted for its truth.
- Whether the Cellmark DNA report, if treated as introduced for its truth, was testimonial under the Sixth Amendment.
Holdings
- The Confrontation Clause does not bar an expert from expressing an opinion based on facts made known to the expert when the related out-of-court statements are not admitted to prove the truth of the matters asserted. On the record of this bench trial, Lambatos's testimony concerned a DNA match and did not use the Cellmark report as substantive proof of the report's underlying assertions.
- The Cellmark report was not testimonial for purposes of the Confrontation Clause because it was prepared before Williams was identified or suspected, primarily to identify an unknown rapist, and lacked the formalized accusatory character of affidavits, depositions, prior testimony, or confessions.
Key quotations
“We now conclude that this form of expert testimony does not violate the Confrontation Clause because that provision has no application to out-of-court statements that are not offered to prove the truth of the matter asserted.” (567 U.S. at 59)
“For the two independent reasons explained above, we conclude that there was no Confrontation Clause violation in this case.” (567 U.S. at 73)
Factual background
A victim reported that she had been abducted and raped, and medical personnel collected vaginal swabs. The Illinois State Police laboratory sent the swabs to Cellmark Diagnostics Laboratory, which generated a male DNA profile; a state analyst later compared that profile with a profile derived from Williams's blood and found a match. At Williams's bench trial, Sandra Lambatos testified about the match even though she had not performed or observed Cellmark's testing, and the Cellmark report itself was not admitted into evidence.
Procedural history
After a bench trial in Illinois state court, petitioner was convicted of aggravated criminal sexual assault, aggravated kidnapping, and aggravated robbery. The Illinois Appellate Court affirmed in relevant part, holding that the Cellmark report was not admitted for its truth. The Supreme Court of Illinois affirmed, and the United States Supreme Court granted certiorari and affirmed.