Williams v. Illinois, 132 S. Ct. 2221

Bench trial in Illinois for rape; DNA evidence linked petitioner to victim via Cellmark profile; Cellmark provided DNA profile from semen on victim's vaginal swabs; Lambatos, ISP analyst, testified comparing Cellmark profile to petitioner’s profile without Cellmark lab testifying; Cellmark report itself was not admitted into evidence; Illinois courts treated Lambatos’ testimony as admissible to explain basis for her opinion under Rule 703; plurality held no Confrontation Clause violation; majority affirmed Illinois, rejected by dissents; Court discussed Crawford v. Washington framework and distinction between not-for-truth basis testimony and testimonial statements; decision emphasizes bench-trial context and potential safeguards

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crawford bars expert opinion based on inadmissible underlying facts	Williams argues basis facts are testimonial	State argues not-for-truth basis evidence is permissible	No Confrontation Clause violation on basis testimony
Whether Cellmark report (if admitted for truth) would violate Confrontation Clause	Cellmark report would be testimonial	No testimonial violation; report not admitted for truth in this case	No Confrontation Clause violation even if admitted for truth (as per plurality/dissent views)
Whether bench trial affects Confrontation Clause analysis in expert basis testimony	Trial judge could misinterpret basis testimony	Bench trial allows judge to understand limited purpose	Context matters; plurality’s approach remains constitutional, though debate persists
Whether use of Cellmark statements as basis for Lambatos’ opinion is permissible under Rule 703	Basis evidence allowed to evaluate expert’s opinion	Disclosures should not be used for truth; risks Confrontation Clause violation	Disclosures may be allowed to explain basis; still requires confrontation if used for truth (depending on rationale)

Crawford v. Washington, 541 U. S. 36 (U.S. 2004) (constitutional Confrontation Clause—testimonial statements require cross-examination)
Melendez-Diaz v. Massachusetts, 557 U. S. 305 (U.S. 2009) (forensic reports treated as testimonial certificates)
Bullcoming v. New Mexico, 564 U. S. 647 (U.S. 2011) (surrogate testimony not allowed for forensic reports; must confront actual analyst)
Davis v. Washington, 547 U. S. 813 (U.S. 2006) (ongoing emergency exception; contrast with testimonial statements)
Tennessee v. Street, 471 U. S. 409 (U.S. 1985) (not-for-truth use of out-of-court statements to compare differing accounts)