Paderes v. Texas (original by judge newell)
Annotate this CaseAppellant, a member of the Houston-area SPPL street gang, gathered a group of gang members and entered the apartment of Rafael Sanchez Cantu and Abelardo Sanchez to attempt to steal money and drugs. In the course of the robbery, both Cantu and Sanchez were shot and killed. Appellant gave a fellow gang member, Jessica Perez, the T-shirt he had worn during the crime and asked her to wash it. She did not. Instead, she informed the police who then recovered the shirt from Perez and sent it to Identigene, a private forensic laboratory, for DNA testing. DNA testing of a bloodstain on appellant’s shirt matched one of the victims. At trial, the State called Robin Freeman, the forensic-laboratory director for Identigene, to testify about the DNA analyses in appellant’s case. The record was unclear about whether Freeman herself created a report based on her opinions, but even if she did, the State did not admit any such report into evidence. The State offered only Freeman’s opinion testimony. Appellant objected, arguing that he was entitled to cross-examine the people who actually conducted the testing on which the expert opinion was based. The trial judge overruled appellant’s objection, and appellant was ultimately convicted of capital murder and sentenced to life in prison without the possibility of parole. The issue raised on appeal to the Court of Criminal Appeals was whether the admission of a supervising DNA analyst’s opinion regarding a DNA match violated the Confrontation Clause when that opinion was based upon computer-generated data obtained through batch DNA testing. Neither the Texas Court nor the United States Supreme Court squarely answered this question. In this case, the Texas Court held that it did not. Consequently, the Court affirmed the court of appeals’ holding that the admission of the supervising analyst’s testimony did not violate the Confrontation Clause.
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