State v. Miller
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The Court of Appeals affirmed the judgment of the trial court convicting Defendant of first-degree rape and other offenses, holding that the trial court did not violate Defendant's constitutional rights by allowing the technical review of a report analyzing DNA evidence to testify about the results of that analysis without requiring the primary author of the report to be available for cross-examination.
In 2008, an unidentified assailant sexually assaulted a nineteen-year-old woman in her apartment. Forensic evidence was collected from the woman's body and from her apartment, and forensic scientists generated a DNA profile from the evidence for an "unknown male #1." Nine years later, the FBI's Combined DNA Index System produced Defendant as a match for "unknown male #1." Defendant was subsequently convicted with several offenses relating to the sexual assault. Thomas Hebert was the primary author of two reports that analyzed and/or compared DNA evidence relevant to this case. The State did not call Hebert as a witness and instead offered the testimony of two other Forensic Services Division analysts in Hebert's stead. The court of special appeals reversed the convictions, concluding that the trial court violated Defendant's constitutional rights to confrontation. The Court of Appeals reversed, holding that Defendant's constitutional rights were not violated under the circumstances of this case.
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