Smith v. Arizona

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Supreme Court of the United States
Smith v. Arizona
Term: 2023
Important Dates
Argued: January 10, 2024
Decided: June 21, 2024
Outcome
vacated and remanded
Vote
9-0
Majority
Elena Kagan • Chief Justice John Roberts • Clarence Thomas (as to Parts I, II, and IV) • Samuel Alito • Sonia Sotomayor • Neil Gorsuch (as to Parts I, II, and IV) • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Clarence Thomas (partial) • Samuel Alito (concurring in judgment), joined by Chief Justice John Roberts • Neil Gorsuch (partial)

Smith v. Arizona is a case that was decided by the Supreme Court of the United States on June 21, 2024, during the court's October 2023-2024 term. The case was argued before the Court on January 10, 2024.

In a unanimous ruling, the Court vacated the Arizona Court of Appeals' judgment and remanded the case for further proceedings, holding, "When an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth."[1] Justice Elena Kagan authored the majority opinion of the Court. Justices Clarence Thomas and Neil Gorsuch joined as to Parts I, II, and IV. Justices Thomas and Gorsuch filed partial concurrences. Justice Samuel Alito filed an opinion concurring in the judgment, joined by Chief Justice John Roberts. Click here for more information about the ruling.


HIGHLIGHTS
  • The issue: The case concerned the confrontation clause of the Sixth Amendment related to expert witness testimony. Click here to learn more about the case's background.
  • The questions presented:"Whether the Confrontation Clause of the Sixth Amendment permits the prosecution in a criminal trial to present testimony by a substitute expert conveying the testimonial statements of a nontestifying forensic analyst, on the grounds that (a) the testifying expert offers some independent opinion and the analyst’s statements are offered not for their truth but to explain the expert’s opinion, and (b) the defendant did not independently seek to subpoena the analyst."[2]
  • The outcome: The U.S. Supreme Court vacated the Arizona Court of Appeals' judgment and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the Arizona Court of Appeals. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 2019, Jason Smith was charged with, and pleaded not guilty to, five drug-related offenses—including possession of methamphetamine and marijuana with the intent to sell—in the Yuma County Superior Court in Arizona. Department of Public Safety (DPS) forensic scientist Elizabeth Rast completed the laboratory analysis of the substances but did not testify at trial. DPS forensic scientist Greggory Longoni testified at trial while referencing Rast's notes. Smith was convicted and sentenced to four years imprisonment.[3][4][5][6]

    On appeal, Smith challenged Longoni's testimony, arguing that it violated Smith's constitutional right to confront witnesses against him under the Confrontation Clause. The Arizona Court of Appeals affirmed Smith’s conviction and rejected his claim regarding Longoni’s testimony. Judge Paul McMurdie delivered the opinion of the court:[3][4][5]

    " Here, as in Karp, Longoni presented his independent expert opinions permissibly based on his review of Rast’s work, and he was subject to Smith’s full cross-examination. Longoni thus did not act as a “mere conduit” for her conclusions. See also Karp at 124, ¶ 13 (finding no hearsay [*8] violation when an expert testifies “to otherwise inadmissible evidence, including the substance of a non-testifying expert’s analysis, if such evidence forms the basis of the expert’s opinion”). Nor did the State introduce Rast’s opinions or any of her work-product documents into evidence. Had Smith sought to challenge Rast’s analysis, he could have called her to the stand and questioned her, but he chose not to do so. See Williams v. Illinois, 567 U.S. 50, 58–59 (2012) (A defendant “who really wishes to probe the reliability of the . . . testing done in a particular case” may subpoena those involved in the testing process and question them at trial.). Given these circumstances, Smith was not deprived of his confrontation rights.


    Even so, Smith asserts three United States Supreme Court cases—Bullcoming v. New Mexico, 564U.S. 647 (2011), Melendez-Diaz v. Massachusetts, 557U.S. 305 (2009), and Williams—require the exclusion of Longoni’s testimony. Bullcoming and Melendez-Diaz do not apply here because those cases involved the unconstitutional admission of testimonial documents prepared by non-testifying witnesses. Bullcoming, 564 U.S. at 663–65; Melendez-Diaz, 557 U.S. at 307–11. Nor does Williams entitle Smith to relief, given that Williams informed our analysis in Karp. 236 Ariz. at 124, ¶¶ 11–14.Moreover, “Williams is a plurality decision and hasl imited if any precedential value,” State v. Ortiz, 238 Ariz. 329, 341, ¶ 52 (App. 2015), so it provides “no binding rule for determining when reports are testimonial.” State v. Medina, 232 Ariz. 391, 406, ¶ 60 (2013). Thus, the superior court did not err by admitting Longoni’s testimony.[7]

    		”

    On March 14, 2023, Jason Smith asked SCOTUS to review the case. On September 29, 2023, the U.S. Supreme Court agreed to hear the case argued on its merits docket.


    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    " Whether the Confrontation Clause of the Sixth Amendment permits the prosecution in a criminal trial to present testimony by a substitute expert conveying the testimonial statements of a nontestifying forensic analyst, on the grounds that (a) the testifying expert offers some independent opinion and the analyst’s statements are offered not for their truth but to explain the expert’s opinion, and (b) the defendant did not independently seek to subpoena the analyst.[7] ”

    Oral argument

    Audio

    Audio of oral argument:[8]




    Transcript

    Transcript of oral argument:[9]

    Outcome

    In a unanimous ruling, the Court vacated the Arizona Court of Appeals' judgment and remanded the case for further proceedings, holding, "When an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth."[1] Justice Elena Kagan authored the majority opinion of the Court. Justices Clarence Thomas and Neil Gorsuch joined as to Parts I, II, and IV. Justices Thomas and Gorsuch filed partial concurrences. Justice Samuel Alito filed an opinion concurring in the judgment, joined by Chief Justice John Roberts.

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    " The question presented here concerns the application of those principles to a case in which an expert witness restates an absent lab analyst’s factual assertions to support his own opinion testimony. This Court has held that the Confrontation Clause’s requirements apply only when the prosecution uses out-of-court statements for “the truth of the matter asserted.” Crawford, 541 U. S., at 60, n. 9. Some state courts, including the court below, have held that this condition is not met when an expert recites another analyst’s statements as the basis for his opinion. Today, we reject that view. When an expert conveys an absent analyst’s statements in support of his opinion, and the statements provide that support only if true, then the statements come into evidence for their truth. As this dispute illustrates, that will generally be the case when an expert relays an absent lab analyst’s statements as part of offering his opinion. And if those statements are testimonial too—an issue we briefly address but do not resolve as to this case—the Confrontation Clause will bar their admission.[7] ”
    —Justice Elena Kagan

    Concurring opinions

    Justice Thomas

    Justice Clarence Thomas filed an opinion concurring in part.

    In his concurring opinion, Justice Thomas wrote:[1]

    " I join the Court in all but Part III of its opinion. The Sixth Amendment’s Confrontation Clause provides: “In all criminal prosecutions, the accused shall enjoy the right . . . to be confronted with the witnesses against him.” This Clause bars the admission of an absent witness’s testimonial statements for their truth, unless the witness is unavailable and the defendant previously had an opportunity to cross-examine that witness. See Crawford v. Washington, 541 U. S. 36, 50–56, 60, n. 9 (2004). Today, the Court correctly concludes that “[w]hen an expert conveys an absent analyst’s statements in support of his opinion, and the statements provide that support only if true, then the statements come into evidence for their truth.” Ante, at 2; see also Williams v. Illinois, 567 U. S. 50, 106 (2012) (THOMAS,J., concurring in judgment). But, a question remains whether that analyst’s statements were testimonial. I agree with the Court that, because the courts below did not consider this question, we should remand for the Arizona Court of Appeals to answer it in the first instance. Ante, at 19–20. But, I disagree with the Court’s suggestion that the Arizona Court of Appeals should answer that question by looking to each statement’s “primary purpose.”


    ... In my view, the Arizona Court of Appeals should consider on remand whether the statements at issue have the requisite formality and solemnity to qualify as testimonial. If they do not, the Confrontation Clause poses no barrier to their admission.[7]

    		”
    —Justice Clarence Thomas


    Justice Gorsuch

    Justice Neil Gorsuch filed an opinion concurring in part.

    In his concurring opinion, Justice Gorsuch wrote:[1]

    " I cannot join, however, the Court’s discussion in Part III about when an absent analyst’s statement might qualify as “testimonial.” See ante, at 19–21. As the Court says, “that issue is not now fit for our resolution.” Ante, at 19. It was not part of the question presented for our review, nor was it the focus of the decision below. Ante, at 19–20. In fact, the State devoted so little attention to the “testimonial” issue in the Arizona courts that any argument it might make on the subject on remand may be forfeited. Ante, at 20. Further, the Court’s thoughts on the subject are in no way necessary to the resolution of today’s dispute. What makes a statement testimonial, the Court notes, is an entirely “separate” issue.


    Nor am I entirely sure about the guidance found in Part III. The Sixth Amendment protects the accused’s “right . . . to be confronted with the witnesses against him.” As the Court sees it, whether a statement being offered for its truth and tendency to inculpate a defendant triggers that right depends “on the ‘primary purpose’ of the statement, and in particular on how it relates to a future criminal proceeding.” I cannot help but wonder whether that is correct.

    ... I am concerned, as well, about the confusion a “primary purpose” test may engender. Does it focus, for example, on the purposes an objective observer would assign to a challenged statement, see ante, at 3 (referencing the “‘objective witness’ ”), the declarant’s purposes in making it, see ante, at 21 (asking “why Rast created the report or notes”), the government’s purposes in “ ‘procur[ing]’ ” it, see ante, at 3, or maybe still some other point of reference? Even after we figure out a statement’s purposes, how do we pick the primary one out of the several a statement might serve?

    ... Some time ago, Chief Justice Marshall charged the judiciary with “be[ing] watchful of every inroad” on the accused’s right to be confronted with the witnesses against him. United States v. Burr, 25 F. Cas. 187, 193 (No. 14,694) (CC Va. 1807). With that cautionary note in mind, I respectfully concur in all but Part III of the Court’s opinion.[7]

    		”
    —Justice Neil Gorsuch


    Justice Alito

    Justice Samuel Alito filed an opinion concurring in the judgment, joined by Chief Justice John Roberts.

    In his concurrence, Justice Alito wrote:[1]

    " Today, the Court inflicts a needless, unwarranted, and crippling wound on modern evidence law. There was a time when expert witnesses were required to express their opinions as responses to hypothetical questions. But eventually, this highly artificial, awkward, confusing, and abuse-laden form of testimony earned virtually unanimous condemnation. More than a century ago, judges, evidence scholars, and legal reform associations began to recommend that courts abandon the required use of hypotheticals, and more than 50 years ago, the Federal Rules of Evidence did so. Now, however, the Court proclaims that a prosecution expert will frequently violate the Confrontation Clause when he testifies in strict compliance with the Federal Rules of Evidence and similar modern state rules. Instead,the Court suggests that such experts revert to the form that was buried a half-century ago. Ante, at 18. There is no good reason for this radical change.


    ... For more than a half-century, the Federal Rules of Evidence and similar state rules have reasonably allowed experts to disclose the information underlying their opinion. Because the Court places this form of testimony in constitutional doubt in many cases, I concur only in the judgment.[7]

    		”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, Smith v. Arizona, decided June 21, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "JASON SMITH v. STATE OF ARIZONA," CERT. GRANTED September 29, 2023
    3. ↑ 3.0 3.1 U.S. Supreme Court, "Smith v. Arizona ON PETITION FOR A WRIT OF CERTIORARI," filed March 14, 2023
    4. ↑ 4.0 4.1 Arizona Court of Appeals, Division One, "Arizona v. Smith Appeal from the Superior Court in Yuma County," filed July 14, 2022
    5. ↑ 5.0 5.1 SCOTUSblog, "Justices to hear cross-examination dispute over drug analyst’s testimony," January 9, 2024
    6. ↑ SCOTUSblog, "Government power, from federal agencies to counties, highlights January session," January 8, 2024
    7. ↑ 7.0 7.1 7.2 7.3 7.4 7.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 10, 2024
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 10, 2024
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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