Smith v. Arizona
Facts
Arizona officers found Smith in a shed with suspected drugs and related items. DPS analyst Elizabeth Rast tested the seized items, prepared notes and a signed report, and concluded that certain items contained usable quantities of methamphetamine, marijuana, and cannabis. Before trial, Rast left the lab, and the State called analyst Greggory Longoni instead to provide an 'independent opinion' based on his review of Rast's records. At trial, Longoni described what Rast's records said about the tests, procedures, and results, and then gave matching opinions identifying the substances.
Issue
Whether the Confrontation Clause permits the State to use a substitute expert to convey an absent forensic analyst's statements as the basis for the substitute's opinion on the theory that those statements are not admitted for their truth. The Court did not resolve whether the specific statements here were testimonial.
Rule
For Confrontation Clause purposes, when an expert conveys an absent analyst's out-of-court statements in support of the expert's opinion, and those statements provide support only if true, the statements are admitted for their truth. A state evidence rule labeling such material as basis evidence does not control the constitutional inquiry; courts must independently determine whether the statements were used for their truth.
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
- The court's holding and reasoning
- Doctrine tests, pitfalls & exam hypotheticals
- 10 practice questions + 4 AI-graded essays on this case
Test yourself
Assuming Owen's statements are testimonial, does the Sixth Amendment permit this testimony on the theory that Owen's statements were offered only as the basis for Nora's opinion?