Smith v. Arizona

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Smith v. Arizona
Seal of the United States Supreme Court.svg
Argued January 10, 2024
Decided June 21, 2024
Full case nameJason Smith v. State of Arizona
Docket no. 22-899
Citations602 U.S. ___ ( more )
Argument Oral argument
Case history
Priorjudgement for the defendant, State v. Smith; Arizona Court of Appeals, 1 CA-CR-21-051; Certiorari granted on September 29, 2023
SubsequentVacated and remanded
Questions presented
Does the Confrontation Clause of the Sixth Amendment permit the prosecution in a criminal trial to present testimony by a substitute expert conveying the testimonial statements of a non-testifying forensic analyst?
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.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Neil Gorsuch  · Brett Kavanaugh
Amy Coney Barrett  · Ketanji Brown Jackson
Case opinions
MajorityKagan, joined by Sotomayor, Kavanaugh, Barrett, Jackson
MajorityThomas, joined by Gorsuch (Parts I, II IV)
ConcurrenceGorsuch, joined by Thomas (In part)
ConcurrenceAlito, joined by Roberts
Laws applied
Const. Amend. VI

Smith v. Arizona, 602 U.S. ___ (2024), is a decision of the Supreme Court of the United States case in which the court held that 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] [2]

Contents

The case revolves around Jason Smith, who was charged with five-related drug offenses including, possession of methamphetamine and marijuana with intent to sell, Smith pleaded not guilty to all charges. At the trial, a forensic scientist of Department of Public Safety (DPA) named Elizabeth Rast, did a laboratory analysis at the substances but did not testify at the trial. Another DPA scientist named Greggory Longoni, testified at the trial while referencing Rast's notes. Smith was convicted and sentenced to four years of imprisonment. Smith appealed to the Arizona Court of Appeals, arguing that Longoni's testimony violated his constitutional right to confront witnesses against him under the Confrontation Clause but the court affirmed his conviction.

In a unanimous decision, Justice Elena Kagan wrote the majority opinion.

Background

In December 2019, around 6:30 A.M., police officers with the Yuma County Narcotics Task Force arrived at Smith's father's house in Yuma County, Arizona to conduct a search warrant. A double-wide trailer, two travel trailers and a shed was found on the property, when the authorities approached a shed, they smelled a "overwhelming odor of fresh marijuana and burnt marijuana", After the officers ordered Smith to turn around and put his hands on the back, an officer had to remove him forcibly from the shed. When the officers took him to the ground to detain him, he refused to put his hand to his back and yelling that the officers were "illegaly trespassing" and "harassing" him. When the officers placed him into the patrol vehicle, the officers also detained eleven individuals from the property, including two individuals who had been in the shed and Smith's father who's ill and needs to be under medical supervision. Once inside the shed, the officers described the room turned into a "makeshift room", containing a bed, a couch, a workbench, a cabinet, a small refrigerator and scattered clothes. During their search, they found six pounds of marijuana on the ceiling, ten grams of marijuana in a dish, they also discovered marijuana in various jars, a meth pipe, a marijuana flower, cannabis wax and methamphetamine. The Superior Court of Yuma County charged him of five counts of felonies, including the possessing of dangerous drugs with intended to sale, and was sentenced in four years of imprisonment. [3]

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References

  1. SMITH v. ARIZONA United States Supreme Court
  2. "Justices send expert witness question back to state court". SCOTUSblog. 21 June 2024. Retrieved 4 November 2024.
  3. STATE v. SMITH ARIZONA COURT OF APPEALS