Law School Case Brief
Williams v. Illinois - 567 U.S. 50, 132 S. Ct. 2221 (2012)
The abuses that the United States Supreme Court has identified as prompting the adoption of the Confrontation Clause share the following two characteristics: (a) they involve out-of-court statements having the primary purpose of accusing a targeted individual of engaging in criminal conduct and (b) they involve formalized statements such as affidavits, depositions, prior testimony, or confessions.
At petitioner's bench trial for rape, Sandra Lambatos, a forensic specialist at the Illinois State Police lab, testified that she matched a DNA profile produced by an outside laboratory, Cellmark, to a profile the state lab produced using a sample of petitioner's blood. She testified that Cellmark was an accredited laboratory and that business records showed that vaginal swabs taken from the victim, L. J., were sent to Cellmark and returned. She offered no other statement for the purpose of identifying the sample used for Cellmark's profile or establishing how Cellmark handled or tested the sample. Nor did she vouch for the accuracy of Cellmark's profile. The defense moved to exclude, on Confrontation Clause grounds, Lambatos' testimony insofar as it implicated events at Cellmark, but the prosecution said that petitioner's confrontation rights were satisfied because he had the opportunity to cross-examine the expert who had testified as to the match. The prosecutor argued that Illinois Rule of Evidence 703 permitted an expert to disclose facts on which the expert's opinion is based even if the expert is not competent to testify to those underlying facts, and that any deficiency went to the weight of the evidence, not its admissibility. The trial court admitted the evidence and found petitioner guilty. Both the Illinois Appellate Court and the State Supreme Court affirmed, concluding that Lambatos' testimony did not violate petitioner's confrontation rights because Cellmark's report was not offered into evidence to prove the truth of the matter asserted.
Did the form of expert testimony violate the Confrontation Clause?
The Court concluded that the form of expert testimony given in this case does not violate the Confrontation Clause. 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.
Access the full text case
Not a Lexis Advance subscriber? Try it out for free.
Be Sure You're Prepared for Class