State v. Katherine Lea Stanfield, 158 Idaho 327

Stanfield was convicted at a May–June 2012 jury trial of first-degree murder by aggravated battery on a child under twelve for the death of W.F.
W.F. died December 13, 2009, after severe head trauma with an autopsy revealing axonal brain injury that clinicians attributed to non-accidental trauma.
The State hired neuropathologist Dr. Lucy Rorke-Adams to examine brain tissue to determine the cause of death; she based conclusions on slides prepared by a laboratory technician.
Stanfield objected to Dr. Rorke-Adams’ testimony as violating the Sixth Amendment Confrontation Clause and as impermissible hearsay; the district court overruled the objection.
Seven medical experts testified for the prosecution and three for the defense; Dr. Rorke-Adams testified regarding her examination and conclusions drawn from the slides.
The district court instructed the jury that it need not find an intent to kill for first-degree murder under the stated theory, and the jury convicted Stanfield.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confrontation Clause applicability to testifying expert relying on non-testifying lab data	Stanfield argues the lab technician’s actions were testimonial and the state should have called the technician.	Stanfield contends the expert’s testimony violated confrontation rights by relying on the technician’s assertions.	No Confrontation Clause violation; expert relied on independent evaluation and control data.
Hearsay foundations for expert testimony based on lab procedures	Stanfield asserts the testimony reflected hearsay from the technician about slides and labeling.	State argues Rule 703 allows experts to rely on routine lab procedures and data.	No reversible hearsay error; testimony satisfied Rule 703 balancing and non-disclosure of underlying inadmissible materials.
Jury instruction on elements of first-degree murder by aggravated battery	Stanfield contends the instruction incorrectly required no specific intent to kill.	Carver precedent supports the instruction allowing conviction without proof of intent to kill.	Instruction proper; aligned with Carver and due-process standards.

Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (forensic reports are testimonial when their primary purpose is evidentiary)
Bullcoming v. New Mexico, 131 S. Ct. 2705 (U.S. 2011) (forensic certificates are testimonial and require live testimony from the certifying analyst)
Williams v. Illinois, 132 S. Ct. 2221 (U.S. 2012) (discussed limits of using others’ testimonial statements when not admitted into evidence; context-specific"} ,{)