California Court of Appeal

Defendant's conviction for first degree murder is once again reaffirmed, upon consideration of Williams v. Illinois, because no violation of the Sixth Amendment's Confrontation Clause occurred in the admission of the DNA test reports, where: 1) although the laboratory personnel who prepared said reports did not testify at trial but a supervisor did testify; 2) the DNA reports lack the solemnity and formality required to be deemed testimonial; 3) DNA test reports are not testimonial in part due to practical considerations, and in part because their primary purpose is not to accuse a targeted individual; and 4) even if the one DNA report that implicated defendant should not have been allowed in evidence, the error was harmless.

Appellate Information

• Decided 04/19/2013
• Published 04/19/2013

Judges

• RUBIN

Court

• California Court of Appeal

Counsel