Young v. United States
2013 D.C. App. LEXIS 138
D.C.2013Background
- Young was convicted of kidnapping and rape based on an FBI DNA examiners’ match.
- Craig did not personally perform the testing; she relied on lab subordinates’ data and reports.
- Young moved to discover frequencies of DNA profile matches in NDIS; court denied.
- Craig testified about DNA testing and random-match probabilities, relaying others’ work and results.
- The Confrontation Clause issue: admitting Craig’s testimony without calling the testifying scientists.
- Court reverses for a new trial due to Confrontation Clause error; discovery ruling stands.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Confrontation Clause violation by surrogate testimony | Young | Government | Confrontation violated; reversal required |
| Discovery of NDIS match data and timing | Young | Government | Discovery denial affirmed; not material or untimely |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial hearsay and confrontation standards)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (forensic testing must be confronted; test reports are testimonial)
- Bullcoming v. New Mexico, 131 S. Ct. 2705 (U.S. 2011) (surrogate testimony cannot substitute for the testifying analyst)
- Gardner v. United States, 999 A.2d 55 (D.C. 2010) (DNA testimony from non-testifying experts can violate Confrontation)
- Williams v. Illinois, 132 S. Ct. 2221 (U.S. 2012) (fractured decision on whether DNA reports are testimonial)
- Marks v. United States, 430 U.S. 188 (U.S. 1977) (disparate opinions; framework for dealing with fractured holdings)