State v. Hurt, 367 N.C. 80 (Jun. 27, 2013)

In a substitute analyst case, the court per curiam and for the reasons stated in Ortiz-Zape (above, under substitute analysts), reversed the Court of Appeals’ decision in State v. Hurt, 208 N.C. App. 1 (2010) (applying Crawford to a non-capital Blakely sentencing hearing in a murder case and holding that Melendez-Diaz prohibited the introduction of reports by non-testifying forensic analysts pertaining to DNA analysis). Reversing on other grounds, the court did not indicate that Crawford was inapplicable to a non-capital sentencing proceeding.