State of New Jersey, Plaintiff-Respondent v. Reginald Roach A/K/A Reginald W. Holmes, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that the defendant's Sixth Amendment confrontation rights were not violated by the testimony of an analyst who independently reviewed and verified DNA data, even though she did not perform the original testing. The Court applied pre‑Williams Confrontation Clause holdings, distinguishing Bullcoming and emphasizing the adequacy of cross‑examination of the independent reviewer. Justice Albin dissented, arguing that surrogate testimony bypasses the defendant's right to confront the original analyst.