State v. Reginald Roach (068874), 95 A.3d 683

Victim (64) was raped during a home invasion; physical samples (sperm, blood, swabs) were collected and sent to the State Police Forensic Laboratory.
Linnea Schiffner performed DNA testing on the victim samples, produced allele readings and a report excluding an early suspect and producing a perpetrator profile; Schiffner later left the lab and did not testify at trial.
Jennifer Banaag, a different State Lab DNA analyst, tested defendant Roach’s buccal swab, independently reviewed Schiffner’s raw data and report, and prepared a report concluding a match between Roach and the perpetrator profile with a very low population frequency.
At trial defendant objected that admitting Banaag’s testimony about Schiffner’s results violated his Sixth Amendment Confrontation Clause rights; the trial court allowed Banaag to testify and the jury convicted Roach of multiple offenses.
The Appellate Division affirmed; the New Jersey Supreme Court (majority) held that Banaag’s independent, documented review and verification of Schiffner’s raw machine data satisfied confrontation requirements and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admitting testimony from an analyst (Banaag) who did not perform the original testing but who independently reviewed and verified the original analyst’s (Schiffner’s) machine-generated data violates the Confrontation Clause	State: An expert may rely on and testify to conclusions based on another analyst’s results if the testifying expert conducted an independent review and did not merely act as a "conduit"; underlying report not admitted into evidence	Roach: Melendez‑Diaz/Bullcoming require the analyst who actually performed the tests (or was available for cross-exam) because the original testing produced testimonial statements; a surrogate cannot substitute even if he reviewed notes	The Court held confrontation rights were satisfied: Banaag performed an independent, qualified review of the raw, machine‑generated data, verified the allele calls, and formed her own conclusions, so she was not a mere conduit and cross‑examination of her sufficed

Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (established testimonial hearsay must ordinarily be subject to confrontation)
Melendez‑Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (forensic certificates can be testimonial; confrontation required when such reports are admitted)
Bullcoming v. New Mexico, 564 U.S. 647 (U.S. 2011) (surrogate testimony by an analyst who did not perform or observe testing can violate the Confrontation Clause)
Williams v. Illinois, 567 U.S. 50 (U.S. 2012) (fractured opinions on testimonial status of forensic reports and limits of Crawford progeny)
State v. Michaels, 219 N.J. 1 (N.J. 2014) (companion New Jersey decision applying pre‑Williams confrontation principles and recognizing supervisor/independent‑reviewer testimony where independent verification occurs)