Williams v. Illinois

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Evidence
  • Date Filed: June 18, 2012
  • Case #: 10-8505
  • Judge(s)/Court Below: Alito, J., wrote an opinion that was joined by Roberts, C.J., Kennedy and Breyer, J.J. Breyer, J. also wrote a concurrence and Thomas, J. wrote an opinion concurring in the judgment. Kagan, J. dissented and was joined by Scalia, Ginsburg and Sotomayor, J.J.
  • Full Text Opinion

A laboratory report that was not prepared for the purpose of incriminating a targeted suspect is non-testimonial within the meaning of the Confrontation Clause.

At Petitioner's rape trial, a police forensics expert testified that a DNA profile based on DNA found on the victim and prepared by a private lab matched Petitioner’s DNA profile that was prepared by the state's lab. Petitioner argued that the expert's testimony regarding the private lab should be excluded on Confrontation Clause grounds. The trial court admitted the evidence and found Petitioner guilty. The state appellate court and the Illinois Supreme Court affirmed.

The Court concluded that the lab’s report did not violate the Confrontation Clause because it was not prepared for the purpose of accusing a targeted individual nor was it a formalized statement akin to an affidavit or a confession.

The plurality opinion also held that the expert's testimony did not violate the Confrontation Clause, because, even though the expert had no personal knowledge of events that took place at the private lab, the statement was made for the purpose of explaining the assumptions on which the expert based her opinion and not to prove the truth of the matter asserted.

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