Law School Case Brief
Williams v. Illinois - 567 U.S. 50, 132 S. Ct. 2221 (2012)
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.
At petitioner Williams' bench trial in state court 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. The prosecution argued 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 was based even if the expert was 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 an appellate court and the Supreme Court of Illinois 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 Confrontation Clause bar the forensic specialist's testimony?
The Supreme Court of the United States affirmed the state court's judgment finding that there was no Confrontation Clause violation. The Court held that when an expert testified for the prosecution in a criminal case, the defendant had the opportunity to cross-examine the expert about any statements that were offered for their truth. Out-of-court statements that were related by the expert solely for the purpose of explaining the assumptions on which that opinion rested were not offered for their truth and thus fell outside the scope of the Confrontation Clause. Moreover, the Court added that under settled evidence law, an expert may express an opinion that was based on facts that the expert assumed, but did not know, to be true. It was 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 did not demand this formality and, in appropriate cases, permitted an expert to explain the facts on which his or her opinion was based without testifying to the truth of those facts.
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