Conners v. State, 92 So. 3d 676

Conners was convicted by a Pike County jury of two murders and two felon-in-possession charges, with consecutive life and ten-year sentences respectively.
Two forensic reports (ballistics and toxicology) were admitted without live testimony from the analysts who performed the tests.
The defense failed to object to the reports at trial, preserving the issue only for plain error review.
The ballistics report suggested the shells could have been fired from the Mossberg shotgun found at the scene, but could not definitively exclude other firearms; the toxicology report showed caffeine, oxycodone, and metabolite opiates in Conners’s blood.
Conners’s defense theory proposed that drug dealers caused the murders after drugging him; his alibi and physical evidence were contested by investigators and witnesses.
The Mississippi Supreme Court reversed the confrontation issue as harmless error and upheld the conviction, rejecting ineffective-assistance claims upon a showing of no prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation Clause violation from admission of forensic reports	Conners argues the reports were testimonial and admitted without live witness	State contends error, if any, was harmless and non-prejudicial	Harmless error; conviction affirmed for this issue
Ineffective assistance of counsel due to failure to object	Conners asserts trial counsel failed to object to confrontation error and gruesome photos and prior-history evidence	State claims no prejudice; record shows overwhelming evidence against Conners	No ineffective-assistance; no prejudice shown; conviction upheld

Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (forensic reports are testimonial and require live testimony)
Bullcoming v. New Mexico, — U.S. —, 131 S. Ct. 2705 (U.S. 2011) (surrogate testimony cannot replace the analyst who performed the test when testimonial)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (core testimonial statements protected by Confrontation Clause)
McGowen v. State, 859 So. 2d 320 (Miss. 2003) (witnesses intimately involved in analysis may testify about the report)
Bullcoming and McGowen line of authority, — (Miss. decisions cited) (discuss how a testifying analyst may satisfy confrontation requirements when involved in analysis)
Corbin v. State, 74 So.3d 333 (Miss. 2011) (confrontation error analyzed under harmless-error standard)
Gossett v. State, 660 So.2d 1285 (Miss. 1995) (confrontation error found harmless in autopsy report scenario)
Barfield v. State, 22 So.3d 1175 (Miss. 2009) (gruesome photographs—rare likelihood of reversible error; must have evidentiary purpose)
Sea v. State, 49 So.3d 614 (Miss. 2010) (ineffective-assistance analysis for prior convictions; rule 609 considerations)