Williams v. Illinois
Opinion Date: June 18, 2012
| Docket: 10-8505 |
Judge: Alito
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.
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