Troy Wilson v. State of Indiana
973 N.E.2d 1211
| Ind. Ct. App. | 2012Background
- Wilson was convicted of Possession of Marijuana and Driving While Intoxicated in Hamilton Superior Court after a jury trial.
- Evidence at trial included a blood test analyzed by Indiana Department of Toxicology analyst Dawn Golden in 2011 for a 2009 blood draw.
- Wilson sought to introduce Dr. Kriger's testimony about audits of the Department’s testing from 2007–2009.
- The trial court sustained objections and excluded Dr. Kriger’s testimony as irrelevant.
- Wilson argued his Confrontation Clause rights were violated and that audit results affected credibility of the Department’s analysis.
- The appellate court affirmed, holding no Confrontation Clause violation and no error in excluding the audit-related testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court abused discretion on Confrontation Clause | Wilson | State | No abuse; confrontation rights satisfied |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (Supreme Court 2004) (establishes confrontation rights in testimonial statements)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (Supreme Court 2009) (requires live testimony of analysts for certificates of analysis)
- Bullcoming v. New Mexico, 564 U.S. _ (Supreme Court 2011) (surrogate testimony not sufficient; analysts must be available for confrontation)