Opinion Date: June 18, 2012
Areas of Law: Constitutional Law, Criminal Law
In petitioner's bench trial for rape, the prosecution called an expert who testified that a DNA profile produced by an outside lab matched a profile produced by the state police lab using a sample of petitioner's blood. At issue was whether Crawford v. Washington precluded the expert witness from testifying in a manner that had long been allowed under the law of evidence. Specifically, did Crawford bar an expert from expressing an opinion based on facts about a case that have been made known to the expert but about which the expert was not competent to testify. Also at issue was whether Crawford substantially impeded the ability of prosecutors to introduce DNA evidence and thus could effectively relegate the prosecution in some cases to reliance on older, less reliable forms of proof. The Court concluded that this form of expert testimony did not violate the Confrontation Clause because the provision had no application to out-of-court statements that were not offered to prove the truth of the matter asserted. Therefore, the Court concluded that the expert's testimony did not violate the Sixth Amendment. As a second, independent basis for the Court's decision, even if the report produced by the outside lab had been admitted into evidence, there would have been no Confrontation Clause violation.