Get Full Government Meeting Transcripts, Videos, & Alerts Forever!
Supreme Court narrows when lab reports can be used through expert testimony in Smith v. Arizona
Summary
In Smith v. Arizona, the Supreme Court unanimously held that lab reports and notes created by an analyst who does not testify may be treated as coming in for their truth, remanding to determine whether the reports' primary purpose was testimonial and thus subject to the Sixth Amendment Confrontation Clause.
Jim Chance, senior judicial education attorney at the Federal Judicial Center, introduced Smith v. Arizona as a unanimous (9–0) Supreme Court decision addressing when expert testimony may rely on a non-testifying analyst's lab data. The court, Justice Kagan writing, focused the inquiry on whether the out-of-court statements were ‘‘testimonial’’ and thus protected by the Sixth Amendment right to confront witnesses.
The case arose after a search produced a substance that a laboratory analyst, Elizabeth Rast, tested. Rast prepared lab notes and reports but then became unavailable to testify; a substitute expert, Gregory Longoni, testified at trial using Rast's notes and lab data and offered his…
Already have an account? Log in
Subscribe to keep reading
Unlock the rest of this article — and every article on Citizen Portal.
- Unlimited articles
- AI-powered breakdowns of topics, speakers, decisions, and budgets
- Instant alerts when your location has a new meeting
- Follow topics and more locations
- 1,000 AI Insights / month, plus AI Chat
