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Williams v. Illinois

Supreme Court of the United States

December 6, 2011, Argued; June 18, 2012, Decided

No. 10-8505

Case Summary

Procedural Posture

In a bench trial, petitioner was convicted of rape after an expert 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. The Illinois Appellate Court and the Illinois Supreme Court affirmed. Certiorari was granted as to whether the testimony was admitted for the truth of the matter asserted, and whether the Confrontation Clause barred the testimony.

Overview

The expert did not identify the sample used for the lab's profile or establish how it handled or tested the sample. Nor did she vouch for the accuracy of that profile. The out-of-court statements related by the expert solely for the purpose of explaining the assumptions on which her opinion rested were not offered for their truth and thus fell outside the scope of the Confrontation Clause. The expert did not vouch for the quality of the lab work. She was asked if there was a computer match generated of the male DNA profile found in semen from the swabs of the victim to a male DNA profile that had been identified as having originated from petitioner. She answered yes. That the matching profile was found in semen from the victim's swabs was a mere premise of the question, and the expert simply assumed that premise to be true. The fact that the lab's profile matched petitioner (identified by the victim as her attacker) was itself confirmation that the sample tested was the victim's sample. The expert referred to the report not to prove the truth of the matter asserted in it, but only to establish that it contained a profile that matched the profile deduced from petitioner's blood.

Outcome

The judgment of the Illinois Supreme Court finding that there was no Confrontation Clause violation was affirmed. 5-4 Decision; 1 opinion; 2 concurrences; 1 dissent.

LexisNexis® Headnotes

 

 

Evidence > ... > Exceptions > Residual Exception > Confrontation Clause Requirements

Constitutional Law > ... > Fundamental Rights > Criminal Process > Right to Confrontation

Evidence > ... > Hearsay > Rule Components > Truth of Matter Asserted

HN1  Confrontation Clause Requirements

The Confrontation Clause does not bar the admission of statements that are not admitted for the truth of the matter asserted.

 

Evidence > Admissibility > Expert Witnesses

HN2  Expert Witnesses

Under settled evidence law, an expert may express an opinion that is based on facts that the expert assumes, but does not know, to be true. It is then up to the party who calls the expert to introduce other evidence establishing the facts assumed by the expert. While it was once the practice for an expert who based an opinion on assumed facts to testify in the form of an answer to a hypothetical question, modern practice does not demand this formality and, in appropriate cases, permits an expert to explain the facts on which his or her opinion is based without testifying to the truth of those facts. Fed. R. Evid. 703.

 

Evidence > ... > Exceptions > Residual Exception > Confrontation Clause Requirements

Constitutional Law > ... > Fundamental Rights > Criminal Process > Right to Confrontation

Evidence > ... > Hearsay > Rule Components > Truth of Matter Asserted

HN3  Confrontation Clause Requirements

When an expert testifies for the prosecution in a criminal case, the defendant has the opportunity to cross-examine the expert about any statements that are offered for their truth. Out-of-court statements that are related by the expert solely for the purpose of explaining the assumptions on which that opinion rests are not offered for their truth and thus fall outside the scope of the Confrontation Clause.

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567 U.S. 50 ; 132 S. Ct. 2221 ; 183 L. Ed. 2d 89 ; 2012 U.S. LEXIS 4658 ; 80 U.S.L.W. 4434; 83 A.L.R. Fed. 2d 649; 23 Fla. L. Weekly Fed. S 355; 2012 WL 2202981

SANDY WILLIAMS, Petitioner v. ILLINOIS

Prior History:  [1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF ILLINOIS.

People v. Williams, 238 Ill. 2d 125, 939 N.E.2d 268, 2010 Ill. LEXIS 971, 345 Ill. Dec. 425 (2010)

Disposition: Affirmed.