Supreme Court of New Jersey

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

August 6, 2014219 N.J. 58

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's judgment, holding that the defendant's Sixth Amendment confrontation rights were not violated by the testimony of a surrogate DNA analyst who independently reviewed and verified the original analyst's data. The Court reasoned that an expert who performs an independent review of forensic data satisfies the Confrontation Clause, even without having performed the original testing. Justice Albin dissented, arguing that the surrogate testimony circumvents the defendant's right to confront the analyst who actually conducted the tests.