Summary
U.S. Supreme Court case regarding the testimony needed to present crime lab results in court. Jason Smith was arrested during a search authorized by a warrant. He was inside a shed on his father's property that was reeking of marijuana. The officers seized six pounds of marijuana, another substance later confirmed to be methamphetamine, and various paraphernalia. Testing at the state crime lab confirmed that the substances were marijuana and methamphetamine.
The analyst who performed the test no longer worked at the lab at the time of trial, so another forensic scientist reviewed the spectra produced by the gas chromatograph/mass spectrometer and gave an expert opinion that the spectra confirmed the substances. The witness relied on lab notes for information on the tests that were run. Long-established federal and state rules of evidence allow an expert witness to rely on outside sources of information that are routinely relied on in the field.
Smith claims that the reliance on lab notes violates the Confrontation Clause of the Constitution and that the state must produce the now-departed analyst as a witness in order to introduce the expert's opinion as evidence. In a "friend of the court" brief, CJLF argues that the term "witness" as understood at the time the Bill of Rights was adopted does not extend so far as to cover the author of the lab notes. The expert who testified is the witness for the purpose of the Sixth Amendment, and the defendant's right to confront him was honored.
The Supreme Court chose not to decide the issue that CJLF briefed, stating that it had not been sufficiently considered in the lower courts. The Supreme Court reversed the state court on another point and sent the case back for consideration of this issue, among others.
