WILLIAMS v. ILLINOIS

Sandy Williams was convicted of two counts of aggravated criminal sexual assault and one count each of aggravated kidnapping and aggravated robbery. Illinois' appellate court affirmed Williams' conviction but reversed the trial court's imposition of a consecutive sentence. On appeal to the Illinois Supreme Court, the defendant argued that the testimony of an Illinois State Police forensic analyst, who relied upon a DNA report prepared by a nontestifying third-party analyst, lacked a sufficient evidentiary foundation. Alternatively, Williams argued that this testimony concerning the report was hearsay presented for the truth of the matter asserted and violated the defendant's Sixth Amendment Confrontation Clause right. The state’s high court affirmed in part and reversed in part, finding that Williams' Sixth Amendment rights weren't violated.