People v. Rutterschmidt, 55 Cal. 4th 650

Golay and Rutterschmidt, both in their 70s, were charged with murdering two men (Vados in 1999; McDavid in 2005) by running them over and collecting life insurance proceeds totaling over $2.2 million.
Insurance applications on both victims listed Golay and Rutterschmidt as beneficiaries, with varying descriptions of their relationships to the victims.
Prosecution theory for McDavid: he was drugged before death; laboratory director Muto testified about tests showing alcohol and sedating drugs based on reports not prepared by him.
Golay challenged the admissibility of the analysts’ reports and whether Muto’s testimony violated the Sixth Amendment confrontation right.
Court of Appeal affirmed; Supreme Court granted Golay’s petition for review to address confrontation-clause issues in light of Crawford, Melendez-Diaz, Bullcoming, and Williams.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lab reports were testimonial and subject to confrontation.	Golay contends the reports were testimonial and the analysts could not be cross-examined.	Rutterschmidt argues Muto’s testimony did not require cross-examining non-testifying analysts.	No reversible error; any error was harmless beyond reasonable doubt.
Whether admission of Muto’s testimony about tests violated confrontation.	Golay asserts confrontation violated by testimony about non-testifying analysts’ results.	State argues Muto’s supervision sufficed; defense had cross-examined Muto.	Harmless beyond reasonable doubt given overwhelming evidence.
Scope of Williams framework in determining testimonial nature of reports.	Golay relies on Williams to deem reports testimonial.	State argues reports not primary accusatory devices; alternative grounds support admissibility.	Court did not need to rely on Williams to uphold harmlessness.

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial vs. non-testimonial statements under confrontation clause)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (laboratory certificates as testimonial affidavits under confrontation clause)
Bullcoming v. New Mexico, 564 U.S. _ (U.S. 2011) (testimony of a non-testifying analyst's report violates confrontation when not independently testified)
Williams v. Illinois, 132 S. Ct. 2221 (U.S. 2012) (plurality held expert testimony may not violate confrontation depending on purpose of testing and testimony)