Case Summaries: Smith v. Arizona; United States v. Rahimi (SCOTUS)

This post summarizes Smith v. Arizona and United States v. Rahimi from the Supreme Court of the United States, decided on June 21, 2024. These summaries, prepared by Phil Dixon (Smith) and Jeff Welty (Rahimi) will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to the present. When an expert witness conveys a non-testifying analyst’s statements in support of the expert's opinion, and the statements provide that support only if true, the statements are offered for the truth of the matter asserted and thus are hearsay implicating the Confrontation Clause Smith v. Arizona, 602 U.S. ___ (2024). Mr. Smith was charged and tried for various drug offenses in Arizona state court. Suspected drugs seized from Smith’s property were sent to a state-run crime lab for testing. Analyst Rast performed the testing, producing notes and a final report on the identity of the substances. She concluded that the items tested were illegal controlled substances. For reasons not apparent from the record, Rast was not available to testify at trial, and state prosecutors called a substitute analyst, Longoni, to provide his independent expert opinion about the drugs. Longoni was not involved in the testing procedures performed by Rast, but he used Rast’s report and notes as the basis of his opinion at Smith’s trial. On appeal, the defendant argued that the use of a substitute analyst to present the conclusions of another, non-testifying analyst violated his rights under the Confrontation Clause of the Sixth Amendment to the [...]