Smith v. Arizona

602 U.S. 779 (2024)

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Nature Of The Case

This section contains the nature of the case and procedural background.

Facts

Police executed a search warrant and inside a shed on the property, they found D. They also found a large quantity of what appeared to be drugs and drug-related items. D was charged with possessing dangerous drugs (methamphetamine) for sale; possessing marijuana for sale; possessing narcotic drugs (cannabis) for sale; and possessing drug paraphernalia. He pleaded not guilty, and the case was set for trial. P sent items seized from the shed to a crime lab for a “full scientific analysis.” Analyst Elizabeth Rast communicated with prosecutors about exactly which items needed to be examined and then ran the requested tests. Rast prepared a set of typed notes and a signed report, both on DPS letterhead, about the testing. The notes documented her lab work and results. They disclosed, for each of eight items: a “[d]escription” of the item; the weight of the item and how the weight was measured; the test(s) she performed on the item, including whether she first ran a “[b]lank” on the testing equipment; the results of those tests; and a “conclusion” about the item’s identity. The signed report then distilled the notes into two pages of ultimate findings, denoted “results/interpretations.” After listing the eight items, the report stated that four “contained a usable quantity of methamphetamine,” three “contained a usable quantity of marijuana,” and one “Contained a usable quantity of cannabis.” P originally planned for Rast to testify about those matters at D’s trial. P replaced Rast with a different DPS analyst as its expert witness. In the time between testing and trial, Rast had stopped working at the lab, for unexplained reasons. And the State chose not to rely on the now-former employee as a witness. P added “Greggory Longoni, forensic scientist (substitute expert).” Longoni had no prior connection to the D case, and P did not claim otherwise. Its amendment simply stated that “Mr. Longoni will provide an independent opinion on the drug testing performed by Elizabeth Rast.” Longoni prepared for trial by reviewing Rast’s report and notes. When Longoni took the stand, he referred to those materials and related what was in them, item by item by item. After telling the jury in detail what Rast’s records conveyed about her testing of the items, Longoni offered an “independent opinion” of their identity. D was convicted and appealed claiming his right to confrontation was violated. P disagreed. In its view, Longoni testified about “his own independent opinions,” even though making use of Rast’s records. The Court of Appeals affirmed. It reasoned that the “underlying facts” are “used only to show the basis of [the in-court witness’s] opinion and not to prove their truth.” The Supreme Court granted certiorari.

Issues

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Holding & Decision

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Legal Analysis

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