DNA

Williams v. Illinois

Issues

Does it violate the Confrontation Clause to allow an expert witness, who did not prepare the forensic DNA report, to give testimony concerning the report?

 

Petitioner, Sandy Williams, was charged with sexual assault on 22-year-old L.J in 2000. At trial, the prosecution called an expert witness to testify about DNA test results that identified Williams as the assailant. He moved to strike the evidence under the Sixth Amendment’s Confrontation Clause because the testifying witness had not performed the DNA tests. The court denied his motion and convicted Williams of sexual assault, kidnapping, and robbery. He contends that allowing an expert witness to testify regarding forensic reports when the witness did not prepare the reports violates the Confrontation Clause. Williams insists that he must have the opportunity to cross-examine the analysts that prepared the reports, particularly because DNA test results are prone to error or manipulation. Respondent, the State of Illinois, argues that allowing the expert witness to testify does not violate the Confrontation Clause because the witness was applying her own independent analysis and opinions concerning the report.

Questions as Framed for the Court by the Parties

Whether a state rule of evidence allowing an expert witness to testify about the results of DNA testing performed by non-testifying analysts, where the defendant has no opportunity to confront the actual analysts, violates the Confrontation Clause.

On February 10, 2000, 22-year-old L.J. walked home after her shift as a clothing store cashier in Chicago. See People v. Williams, 238 Ill. 2d 125, 129 (Ill. 2010). L.J.

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Acknowledgments

The authors would like to thank former Supreme Court Reporter of Decisions Frank Wagner for his assistance in editing this preview.

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