Paredes, Jovany Jampher, 462 S.W.3d 510

Appellant (Paredes) was convicted of capital murder after DNA from a bloodstain on his T-shirt matched a victim; Identigene conducted batch DNA testing.
Identigene’s batch process involved multiple technicians generating raw, computer-produced DNA data; Robin Freeman (lab director) supervised and performed the final interpretation/comparison but did not perform all physical steps.
Freeman testified she compiled the instrument-generated raw data and reached her own conclusion that the victim’s DNA matched the stain; the technicians who ran the instruments did not testify and no raw-data reports were admitted into evidence.
Appellant objected under the Sixth Amendment’s Confrontation Clause, arguing he was entitled to cross-examine the technicians who performed the testing.
The Fourteenth Court of Appeals affirmed; after this Court’s remand to consider Burch, the appeals court again upheld admission. This Court granted review to decide whether admission of Freeman’s opinion based on computer-generated batch data violated the Confrontation Clause.
The Court held admission did not violate the Confrontation Clause because Freeman testified to her own independent analysis based on non-testimonial, computer-generated data and was subject to cross-examination.

Issue	Paredes' Argument	State's Argument	Held
Whether admission of a supervising analyst’s DNA-match opinion based on computer-generated batch data violated the Confrontation Clause	Freeman relied on non-testifying technicians’ work; Paredes couldn't confront those analysts about testing errors or protocol lapses	Freeman performed the crucial interpretation herself; the underlying raw data were computer-generated (non-testimonial) and Freeman’s opinion was her own and was subject to cross-examination	Held: No Confrontation Clause violation — expert gave her own testimonial opinion based on non-testimonial computer data and was cross-examined
Whether the testifying expert may serve as a surrogate for non-testifying analysts by relaying their conclusions	Freeman effectively served as a surrogate for the technicians’ conclusions, analogous to disallowed surrogate testimony in Bullcoming/Burch	Freeman did not merely parrot a report; she independently compiled and interpreted instrument data and did not introduce a testimonial lab report	Held: Not a surrogate situation — unlike Bullcoming/Burch, no testimonial report from non-testifying analyst was admitted and the witness had personal knowledge of the analysis

Crawford v. Washington, 541 U.S. 36 (establishes that testimonial statements require an opportunity for cross-examination)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (forensic certificates are testimonial and require analyst testimony)
Bullcoming v. New Mexico, 564 U.S. 647 (surrogate testimony explaining a non-testifying analyst’s lab report violates Confrontation Clause)
Williams v. Illinois, 567 U.S. 50 (plurality/concurrences fractured on rationale; addressed expert testimony relying on another lab’s profile)
Burch v. State, 401 S.W.3d 634 (Tex. Crim. App. 2013) (reviewer who lacked personal knowledge of testing violated the Confrontation Clause)