Williams v. Illinois

Whether a state violates a criminal defendant's constitutional right to be confronted with the witnesses against him when it allows an expert to testify about DNA reports prepared by analysts who do not appear at trial.

Police developed Williams' DNA profile from blood drawn pursuant to a court order following his arrest for charges unrelated to this case. An Illinois State Police ("ISP") forensic biologist matched DNA from Williams to DNA derived from vaginal swabs taken from a rape victim. Williams was arrested on charges of aggravated sexual assault, aggravated robbery, and aggravated kidnapping. A judge convicted Williams following a bench trial. During trial, the ISP forensic biologist testified, over Williams' objection, that in her expert opinion, Williams' DNA profile matched the DNA profile derived from the vaginal swabs taken from the rape victim. The Illinois Supreme Court affirmed Williams' conviction.

On appeal, Williams argues that the court denied his rights under the Confrontation Clause when it allowed expert testimony that relied on DNA analysis developed by an independent lab whose analysts did not testify at trial. Williams argues that, because the DNA reports were testimonial, it was error to allow the state's expert to testify as to the substance of the reports without affording him the opportunity to cross-examine the analysts who prepared the DNA reports. Finally, Williams argues that it is critical that a defendant be given the opportunity to test the accuracy of the analysts' veracity and methodology through cross-examination.