Tyree Brodley v. State of Indiana (mem. dec.), 49A02-1603-CR-613

On May 9, 2014, Tyree Brodley and Pashae Beech argued; Brodley left home carrying guns while wearing a white tank top.
Later that night, witnesses saw a man in a white tank top shoot and kill Terrance Holmes; 20–30 shots fired. The shooter fled and appeared to be shot in the leg.
Officers found Brodley in an alley with a leg wound; a .40 caliber Glock (one of several guns at the scene) was found near him.
A cell phone beside Brodley contained photos of Brodley, his infant, and the Glock showing the same serial number as the gun recovered.
DNA testing of blood on Brodley’s white tank top (performed by Dr. Amjad and reported by lab supervisor Shelley Crispin) matched Brodley; Brodley did not object at trial to Crispin’s testimony.
Brodley was convicted of murder after a bench trial and appealed, arguing admission of the DNA evidence violated his Sixth Amendment confrontation rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of lab supervisor’s testimony about analyst’s DNA results violated Confrontation Clause	State: testimony admissible and supported conviction	Brodley: Crispin relayed Dr. Amjad’s out-of-court statements; he was deprived of right to confront the analyst about methods/results	Court: Even if admission erred, error was not fundamental and was harmless because independent and cumulative evidence supported conviction

Palilonis v. State, 970 N.E.2d 713 (Ind. Ct. App. 2012) (contemporaneous objection requirement to preserve evidentiary claims)
Hoglund v. State, 962 N.E.2d 1230 (Ind. 2012) (standard for fundamental error and harmless-error analysis)