Confrontation Clause Update: Williams v. Illinois and What It Means for Forensic Reports

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Under the new Crawford analysis, a testimonial hearsay statement by a person who does not testify at trial is inadmissible unless the prosecution establishes unavailability and a prior opportunity to cross-examine. Courts have struggled to apply this analysis to various types of forensic reports, including autopsy reports, drug tests and chemical analysts’ affidavits. This bulletin examines Williams v. Illinois, the U.S. Supreme Court’s latest decision applying Crawford to forensic reports, and analyzes its implications on criminal cases in North Carolina.

Download ( Illinois and What It Means for Forensic Reports, 418.14 KB)

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Evidence